Joint Comments to the FDIC re: 60 Day Extension Request on Deposits

Ladies and Gentlemen:

The American Bankers Association, the American Fintech Council, the Bank Policy Institute, the Electronic Transactions Association, the Financial Services Forum, the Financial Technology Association, the Independent Community Bankers of America, the Innovative Payments Association, the Institute of International Bankers, the National Association of Industrial Banks, and the Securities Industry and Financial Markets Association ("the Associations") are requesting an extension to the 60-day comment deadline that was included as part of the FDIC's Request for Information on Deposits ("RFI").

The Associations are requesting an extension of an additional 60 days to provide comments on the RFI. The FDIC intends to gather data on the characteristics that affect the stability and franchise value of different types of deposits to inform calibration of deposit insurance, liquidity and other regulations, reporting and supervisory initiatives. It is essential then, that the FDIC have a robust and accurate data set from which to work, and that any additional reporting requirements be sensible and workable for banks of all sizes and their affiliates, particularly affiliated broker-dealers, and their customers. Given the importance of the RFI and its implications for future changes, the Associations do not believe that 60 days is sufficient time to provide comments.

The RFI contains a wide range of requests for technical and complex information regarding banks' internal processes for monitoring and analyzing various classes of deposits while also requesting an array of information in a broadly open-ended manner. The open-ended nature of the RFI, coupled with the technical nature of the information requested requires a significant amount of research and consideration to ensure that the provided response is specific, comprehensive and addresses each of the key issues raised in the RFI. In addition, the subject matter experts needed to respond are the same ones that would be required to respond to the FDIC's Notice of Proposed Rulemaking on Brokered Deposits, which has been issued concurrently with this RFI. Responding to both regulatory requests within such a short period of time would place an undue burden on the resources of our members.

Download the joint comment letter to read the full text.