Justification - Collaboration Inventory Form 07282023

Federal Deposit Insurance Corporation

550 17th Street NW, Washington, D.C. 20429-9990

550 17th Street NW, Washington, D.C. 20429-9990

July 28, 2023

 

Memorandum to:        Will Bestani

                                    Policy Analyst 

                                    Office of Information and Regulatory Affairs

                                    Office of Management and Budget

 

From:                Jennifer Jones

Counsel

                                    Federal Deposit Insurance Corporation

 

RE: Collaboration Inventory Form User Survey

Under the generic clearance entitled, “Occasional Qualitative Surveys” (3064-0127), the FDIC hereby submits for OMB review the generic survey “Collaboration Inventory Form” This survey will be fielded July - October 2023 as an interagency effort, led by FDIC staff. The purpose of the survey is to collect information from institutions that are interested in participating in the Collaboration Networking Event that will be held during the 2023 Interagency MDI and CDFI Bank Conference.

The FDIC supports five statutory goals¹ in support of minority depository institutions (MDIs). These goals are designed to preserve this small segment of the banking industry that often promotes economic viability of minority and underserved communities. The FDIC has long recognized the importance of MDIs and has historically taken steps to preserve and encourage minority ownership of insured financial institutions. The MDI program is established by the Policy Statement Regarding Minority Depository Institutions, initially adopted by the FDIC Board of Directors in 1990, and updated most recently in June 2021.

In support of these statutory goals, the FDIC has made it a priority to increase engagement and collaboration with, and provide support for, Mission Driven Banks. These include FDIC-insured MDIs and Community Development Financial Institutions (CDFI Banks). Currently, there are approximately 300 MDIs & CDFI Banks nationwide. In addition to the outreach, technical assistance, and training and education that the MDI program provides, another important interagency initiative is to create opportunities for MDIs and CDFI Banks to partner with large and regional banks.

The data collected via the proposed form will only be used by banks that have registered for the 2023 Interagency MDI and CDFI Bank Conference and expressed an interest to participate in the Collaboration Networking Roundtables. Information from this survey will be used to ensure that participants are matched with institutions with aligning interests in relation to partnership and collaboration categories derived from qualifying activities outlined in the Community Reinvestment Act.

After providing bank and point of contact information, users will be asked whether they would like to request support or provide support in the following categories: Financial Support, Lending Opportunities, and Service Opportunities. Each category has a subcategory whereby users will indicate if they would either need or provide the opportunity listed in the subcategory (financial support, human capital support, lending opportunities, product development/delivery/support, technical assistance, training collaboration, shared services, and other opportunities).

To allow the Office of Minority and Community Development Banking to match interested participant banks, this survey will be fielded during a continuous period between July and October 2023. Based on past experience, collecting similar metrics and the capacity limitation of the event, the FDIC estimates that there will be a maximum of 300 responses in total.

The total estimated annual burden for the collection of this information is 225 hours.

Annual Estimated Number of respondents: 300

Estimated Time per response: 45 minutes

Total Estimated Annual Burden: 225 hours

If you have any questions, please let me know. Thank you for your consideration.

1The five goals are to: (1) preserve the number of MDIs; (2) preserve the minority character in cases of merger or acquisition; (3) provide technical assistance to prevent insolvency of institutions not now insolvent; (4) promote and encourage creation of new MDIs; and (5) provide for training, technical assistance, and educational programs.