FDIC Releases Supplemental Guidance on Business Planning

April 8, 2016

On Wednesday, April 6, 2016, the FDIC guidance in the form of supplemental "Questions and Answers" (Q&As) to aid applicants in developing proposals for deposit insurance. The supplemental Q&As, which address business planning, provide additional transparency to the application process and supplement the guidance issued November 20, 2014, through Financial Institution Letter (FIL) 56-2014.

 

Highlights include:

 

  • Part 303 (Subpart B) of the FDIC Rules and Regulations (12 U.S.C. § 1815) sets forth the administrative procedures to apply for deposit insurance.
  • The FDIC Statement of Policy on Applications for Deposit Insurance, which was effective October 1, 1998, provides additional guidance to proposed depository institutions applying for deposit insurance.
  • The FDIC issued Q&As on November 20, 2014, through FIL-56-2014, entitled Guidance Related to the FDIC Statement of Policy on Applications for Deposit Insurance. The Q&As addressed pre-filing meetings, processing timelines, initial capitalization, and initial business plans of de novo institutions.
  • The supplemental Q&As address business plan content with respect to initial submissions, weaknesses identified in submitted plans, and changes in business plans.
  • The FDIC may post additional Q&As as circumstances warrant.