Justification Memo - Uninsured Deposits Survey

Federal Deposit Insurance Corporation

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

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

August 23, 2023

 

Memorandum to:        Will Bestani

                                    Policy Analyst 

                                    Office of Information and Regulatory Affairs

                                    Office of Management and Budget

 

From:                Manny Cabeza

Regulatory Counsel

Legal Division

                                    Federal Deposit Insurance Corporation

 

RE: Review of Estimated Uninsured Deposits Reporting Questionnaire

Under the generic clearance entitled, “Information Collection for Qualitative Research” (3064-0198), the FDIC hereby submits for OMB review the generic survey “Review of Estimated Uninsured Deposits Reporting.” This survey is voluntary and will be fielded in August and September 2023. The purpose of this survey is to confirm the accuracy of uninsured deposits reporting by banking organizations with total consolidated assets of $10 billion or more as of June 30, 2023.

As a general matter, the accuracy of the estimated amount of uninsured deposits is necessary for monitoring the safety and soundness of individual insured depository institutions (IDIs) and the banking system as a whole. The FDIC also uses this line item to calculate the Deposit Insurance Fund (DIF) reserve ratio, which is the ratio of the DIF balance to all insured deposits. The DIF reserve ratio is a key tool used to manage the level of the DIF to maintain public confidence in the U.S. financial system and to resolve failed banks. This line item is also used to calculate quarterly deposit insurance assessments for large banks (generally those with $10 billion or more in assets) and highly complex institutions.

On July 24, 2023, the FDIC issued a Financial Institution Letter that reiterated the responsibility of each IDI to correctly report estimated uninsured deposits in accordance with Call Report instructions.¹ The information collected via the proposed survey will be used to evaluate and confirm the accuracy of the reported amount of estimated uninsured deposits and other related line items on the Call Report. The survey asks institutions to confirm that reported numbers for select types of deposits are consistent with the Call Report instructions and includes a narrative section that asks institutions to provide any additional information that would assist the FDIC to better understand the banks’ reporting.

The FDIC expects to receive approximately 210 responses to this survey. The estimated time per response is approximately 2 hours (120 minutes) and the total estimated annual burden for the survey is 420 hours.

Annual Estimated Number of respondents: 210

Estimated Time per response: 120 minutes

Total Estimated Annual Burden: 420 hours

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

1 FDIC Financial Institution Letter (FIL 37-2023), Estimated Uninsured Deposits Reporting Expectations. https://www.fdic.gov/news/financial-institution-letters/2023/fil23037.html.