Joint Trade Comment Period Extension Request for FDIC Deposit Characteristics Request for Information

Federal Deposit Insurance Corporation
550 17thStreet NW
Washington, DC 20429
Attention: James P. Sheesley, Assistant Executive Secretary
RIN 3064–ZA42

Re:         Request for Information on Deposits – 60 Day Extension Request

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.

Furthermore, the RFI requests information on an extremely wide set of issues ranging from current practices for monitoring deposits to views on potential new account types and their interaction with the deposit insurance regime. Finally, the RFI requests “what additional data, including more granular or more frequently reported data, should be considered for collection” without providing any clear guidance on the type or format of data that should be considered.

The Associations and their members appreciate the opportunity to provide information on the issues raised in the RFI but, at the same time, want to ensure that sufficient time is provided to furnish appropriately detailed and comprehensive responses that thoughtfully consider the issues raised in the RFI. The Associations believe that an additional 60 days will provide the Associations and their members the requisite time to furnish responses and data that fulsomely address the questions and issues raised within the RFI.

Thank you for your consideration of this request. If you have any questions, please contact the undersigned.

Sincerely,

Alison Touhey
SVP, Bank Funding Policy, American Bankers Association

Ian P. Moloney
SVP, Head of Policy and Regulatory Affairs, American Fintech Council

Brett Waxman
SVP, Senior Associate General Counsel, Bank Policy Institute

Scott Talbott
Executive Vice President, Electronic Transactions Association

Sean Campbell
Chief Economist, Head of Policy Research, Financial Services Forum

Angelina Bradfield
Head of Policy, Financial Technology Association

Jenna Burke
EVP, General Counsel, Government Relations and Public Policy, Independent Community Bankers of America

Brian Tate
President and CEO, Innovative Payments Association

Stephanie Webster
General Counsel, Institute of International Bankers

Frank Pignanelli
Executive Director, National Association of Industrial Bankers

Carter McDowell
Managing Director, Associate General Counsel, Securities Industry and Financial Markets Association