Information Technology Functional Guide · 2.5 Conceptual Systems Flow ... 8 Certification of Compliance ... About the Part 370 Information Technology Functional Guide

Information Technology Functional Guide

12 CFR Part 370: Recordkeeping for Timely Deposit Insurance Determination

VERSION 1.0

April 2017

FDIC – Part 370 Recordkeeping Information Technology Functional Guide Version 1.0

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Contents

How to Read This Document ........................................................................................... 1

1 Introduction ................................................................................................................ 2

2 Overview ..................................................................................................................... 3 2.1 Background ............................................................................................................................................... 3 2.2 Key Concepts ........................................................................................................................................... 3 2.3 CI Failure Scenario .................................................................................................................................. 4 2.4 High-Level Process ................................................................................................................................. 6 2.5 Conceptual Systems Flow ...................................................................................................................... 8

3 Process Requirements .............................................................................................. 9 3.1 Deposit Insurance Determination .......................................................................................................... 9 3.2 Pending File (Input, Process, and Output) ......................................................................................... 13

4 Deposit Insurance Determination Requirements ................................................ 18 4.1 Initial Processing .................................................................................................................................... 18 4.2 Right and Capacity and Deposit Insurance Determination .............................................................. 19 4.3 Apply Funds ............................................................................................................................................ 42

5 Output File Generation Requirements .................................................................. 43 5.1 Output File Population – Customer File .............................................................................................. 43 5.2 Output File Population – Account File ................................................................................................ 44 5.3 Output File Population – Account Participant File............................................................................. 44 5.4 Output File Population – Pending File ................................................................................................ 45

6 Control Report Requirements ................................................................................ 46 6.1 Data Movement ...................................................................................................................................... 46 6.2 Data Quality ............................................................................................................................................ 47 6.3 Control Reports ...................................................................................................................................... 48

7 Summary Report Requirements ............................................................................ 49

8 Certification of Compliance .................................................................................... 50

Appendix A Explanation of Output File Generation Capabilities ............................ 51

Appendix B Explanation of Ownership Account Categories ................................... 61

Appendix C Use Cases .................................................................................................. 68

C.1 Single Accounts ................................................................................................... 69

C.1.1 Scenario 1 ............................................................................................................... 69 C.1.1.1 Background ................................................................................................................................... 69 C.1.1.2 Algorithm Application ................................................................................................................ 69 C.1.1.3 Outcome ........................................................................................................................................ 70


C.2 Joint Accounts ........................................................................................................ 74



C.3 Revocable Trust Accounts ..................................................................................... 78





C.4 Irrevocable Trust Accounts .................................................................................. 94


C.4.2 Scenario 2 ............................................................................................................... 97 C.4.2.1 Background ................................................................................................................................... 97 C.4.2.2 Algorithm Application ................................................................................................................ 97 C.4.2.3 Outcome ...................................................................................................................................... 100

C.4.3 Scenario 3 ............................................................................................................. 101 C.4.3.1 Background ................................................................................................................................. 101 C.4.3.2 Algorithm Application .............................................................................................................. 101 C.4.3.3 Outcome ...................................................................................................................................... 104

C.5 Certain Retirement Accounts .............................................................................. 106


C.6 Employee Benefit Plan Accounts ....................................................................... 108



C.7 Business Accounts ............................................................................................... 113


C.8 Government Accounts .......................................................................................... 116


C.9 Mortgage Servicing Accounts ............................................................................. 119


C.10 Accounts held by a Depository Institution (DI) as the Trustee of an Irrevocable Trust ............................................................................................................ 125

C.10.1 Scenario 1 ................................................................................................................ 125 C.10.1.1 Background .................................................................................................................................... 125 C.10.1.2 Algorithm Application ................................................................................................................. 125 C.10.1.3 Outcome ......................................................................................................................................... 127

C.11 Annuity Contract Accounts ............................................................................... 128


C.12 Public Bond Accounts ........................................................................................ 132

C.12.1 Scenario 1 ................................................................................................................ 132 C.12.1.1 Background .................................................................................................................................... 132 C.12.1.2 Algorithm Application ................................................................................................................. 133 C. 12.1.3 Outcome ....................................................................................................................................... 136

C.13 Custodian Accounts for American Indians ....................................................... 138

C.13.1 Scenario 1 ................................................................................................................ 138 C.13.1.1Background ..................................................................................................................................... 138 C.13.1.2 Algorithm Application ................................................................................................................. 138 C.13.1.3 Outcome ......................................................................................................................................... 139

C.14 Accounts of an IDI Pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy ......................................................................... 140



C.15 Fiduciary Account - Broker/Sweep Accounts ....................................................... 142

C.15.1 Scenario 1 ................................................................................................................ 142 C.15.1.1 Background .................................................................................................................................... 142

C.15.2 Scenario 1 - Day 1 ................................................................................................. 142 C.15.2.1 Algorithm Application ................................................................................................................. 143 C.15.2.1.1 Anytown Broker Account ................................................................................................... 143 15.2.1.2 Deposit Insurance Determination for Marci Jones (SGL) ........................................... 143 C.15.2.1.3 Deposit Insurance Determination for XYZ Dredging, Inc. (BUS) .............................. 145 C.15.2.2 Outcome ......................................................................................................................................... 147

C.15.3 Scenario 1 - Day 15 ............................................................................................... 148 C.15.3.1 Overview ........................................................................................................................................ 148 C.15.3.2 Algorithm Application ................................................................................................................. 148 C.15.3.2.1 Anytown Broker Account ................................................................................................... 148 C.15.3.2.2 Deposit Insurance Determination for Anywhere City (GOV1) ................................... 148 C.15.3.2.3 Deposit Insurance Determination for ABC Trust (REV) ............................................... 150 C.15.3.3 Outcome ......................................................................................................................................... 153

Appendix D Acronyms/Abbreviations/Terms ........................................................ 154


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How to Read This Document

Section Summary

1. Introduction Explanation of the goals and intent of the document.

2. Overview Overview of deposit insurance and the deposit insurance determination process.

3. Process Requirements Explanation of the processes and capabilities that the Federal Deposit Insurance Corporation (“FDIC”) expects all Covered Institutions (“CIs") will be able to demonstrate in order to ensure compliance with 12 CFR Part 370 entitled “Recordkeeping for Timely Deposit Insurance Determination” (“Part 370”).

4. Deposit Insurance Determination Requirements

Detailed explanation of calculations that must be performed by the CI to correctly calculate deposit insurance coverage.

5. Output File Generation Requirements

Explanation of requirements for populating data files where the instructions vary by ownership right and capacity (“ORC”).

6. Control Report Requirements Explanation of data checks that a CI must have in place for accuracy, completeness, and compliance with standards and to meet the objectives of the rule.

7. Summary Report Requirements Explanation of high-level summary reporting requirements that a CI must have in place to support accurate deposit insurance calculation process.

8. Certification of Compliance Explanation of the document that a CI must provide to certify that it has implemented and successfully tested its information technology system for compliance with Part 370 during the preceding calendar year.

9. Appendices Appendix A

— Explanation of data-file-generation capabilities that a CI must have for the calculation of deposit insurance coverage.

Appendix B

— Explanation of the 14 ORCs that are recognized by the FDIC in its deposit insurance determination process.

Appendix C

— Use Cases

Appendix D

Explanation of

— Acronyms/Abbreviations/Terms

— Definitions

— Cross-References


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1 Introduction

About the Part 370 Information Technology Functional Guide

This Part 370 Information Technology Functional Guide (“Guide”) serves as a supplemental resource to assist covered institutions (“CIs”) with the implementation of information technology systems capabilities that will be compliant with 12 C.F.R. Part 370 (“Part 370”). The goals of this Guide are to:

— Provide a single, organized source for CI systems capabilities. — Describe the details of the features, function, and other systems aspects that the FDIC believes

should be present in the CI’s recordkeeping, IT, or data environment. This Guide does not contain:

— Detailed business requirements or technical requirements that would support systems development; rather these should be developed by each CI.

— Descriptions of the methodology used to discover, assess, and specify the underlying guidance.

Important Disclaimers This Guide is technical in nature and does not create any rights, substantive or procedural, enforceable at law by any party in any matter. It does not bind covered institutions or the FDIC to a specific course of action. It is not intended to constitute and should not be considered as legal advice. It is not definitive or comprehensive and should not be relied upon for interpretation of the FDIC’s deposit insurance rules. The Federal Register and the Code of Federal Regulations remain the official sources for regulatory information published by the FDIC. This Guide may be used in conjunction with the FDIC’s deposit insurance reference materials found on the FDIC’s website at www.fdic.gov/deposit. In particular, the Financial Institution Employee’s Guide to Deposit Insurance, accessible on the FDIC’s website at www.fdic.gov/deposit/DIGuideBankers.html may prove helpful and illustrative. Note about possible changes to this Guide This version of the Guide reflects the statutory principles and implementing regulations that are effective as of the date of publication. This Guide will be revised on an on-going basis as laws, policies and procedures change and as feedback regarding system architecture, interfaces, capabilities, and limitations is provided to the FDIC by CIs. It is dated as of the most recent revision date. Contact To the extent questions arise regarding Part 370, including the information contained in this Guide, please contact the FDIC at [email protected].

http://www.fdic.gov/deposit


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2 Overview

The FDIC has issued new requirements for all CIs to ensure that depositors have prompt access to insured deposits in the event of a failure. If a CI fails, the FDIC must provide depositors their insured funds "as soon as possible" after failure while also resolving the failed CI in the least costly manner possible.

References to actions to be taken by a CI after the FDIC has been appointed as receiver are intended to be taken at

the direction of or on behalf of the FDIC, as applicable.

2.1 Background

In November 2016, the FDIC approved for publication in the Federal Register a final rule requiring large Insured Depository Institutions (“IDIs”) with two million or more deposit accounts to maintain complete and accurate data on each depositor’s ownership interest in deposit accounts by right and capacity. The IDIs covered by this rule, now CIs, must also develop and maintain IT systems capability to calculate the insured and uninsured amounts for each deposit owner by right and capacity for all deposit accounts. Should a CI fail, this capability will be used by the FDIC to facilitate timely payment of deposit insurance.

Please refer to the Final Rulemaking at 81 FR 87734 (December 5, 2016) and the supplementary information contained therein for more information.

2.2 Key Concepts

2.2.1 Deposit insurance coverage has increased over time

Deposit insurance was established through the Banking Act of 1933 with a standard maximum deposit insurance amount (“SMDIA”) of $2,500. As the economy and banking industry evolved, Congress and the FDIC recognized the need for additional coverage. Consequently, the Federal Deposit Insurance Act and relevant regulations have been amended to both increase the SMDIA and provide for additional coverage through the creation of different ownership “rights and capacities” (“ORCs”). Congress most recently raised the SMDIA to $250,000 in 2010. 2.2.2 Prompt access to insured deposits is essential

Confidence in the FDIC is critical to the public’s confidence in the banking system. No depositor has lost a single penny of insured deposits since the FDIC was established in 1933. Of equal importance, the FDIC strives to make funds available to depositors as soon as possible, often by the next business day after an IDI fails.

2.2.3 Depositors are insured separately at each insured CI

While each depositor’s insurance coverage is limited to the SMDIA for each insurance category, each depositor is insured separately at each CI. A depositor’s coverage in a category at one CI does not affect the depositor’s coverage in that same insurance category for an account at a different CI. 2.2.4 FDIC will rely on the CI’s deposit account records

In the event of the failure of a CI, the FDIC relies upon the deposit account records of the CI to determine the ownership of an account and thereby the amount of the deposit insurance coverage available to each depositor. If the records are complete, clear, and unambiguous, then those records shall be considered binding on the depositor, and the FDIC shall consider no other records on the manner in which the deposits are owned. 2.2.5 Depositors are insured in different ownership “rights and capacities”

Deposit insurance coverage is provided for deposits held in 14 different ORCs. All deposits, whether in one account or multiple accounts, held in an IDI are aggregated and insured for up to the SMDIA for the particular ORC.


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2.2.6 Fiduciary and agency accounts may receive pass-through coverage

Fiduciary or agency accounts may be entitled to receive pass-through deposit insurance coverage. These accounts are established and maintained by third parties on behalf of the beneficial owner of a deposit. These pass-through deposits would be aggregated with all other deposits within the same ORC that the owner may have at the failed CI. 2.2.7 Deposits eligible for FDIC deposit insurance

Deposit insurance coverage only applies to domestic deposits. Non-deposit accounts, such as securities accounts, and deposits at foreign branches are excluded for purposes of deposit insurance calculation.

2.3 CI Failure Scenario

The processes for Part 370 may be conducted in three phases: 1) implementation and initial validation, 2) ongoing auditing and compliance testing, and 3) CI failure. 2.3.1 Implementation period and initial validation

Part 370 sets a three-year time frame for implementation. The FDIC will provide technical guidance and input upon request by a CI during this period. A CI must implement key system functionalities and ensure that all required data is complete and accurate so as to enable performance of an automatic deposit insurance calculation. The data requirements include, but are not limited to, assigning unique identifiers to account owners and assigning each deposit account into one of the 14 ORCs.

Throughout this document, work functions and processes are described in great detail in order to fully portray the functionalities, capacities, and operations that CI systems must be able to perform. Before expiration of the three-year time frame, a CI must submit a certification of compliance signed by the Chief Executive Officer (“CEO”) or Chief Operating Officer (“COO”) of the CI and a summary deposit insurance coverage report, unless an extension is granted. 2.3.2 Ongoing compliance testing

Compliance testing will begin after the expiration of the Part 370 three-year implementation period. The FDIC will test 1) the completeness and accuracy of the CI’s customer and deposit data; and 2) the accuracy of the CI’s insurance calculation and reporting. The CI will 1) address any deficiencies identified during compliance testing; and 2) test processes to integrate data concerning alternate recordkeeping and exception accounts.

A CI’s systems must be compliant with Part 370 and, at a minimum, be capable of generating the output files for the Customer File, Account File, Account Participant File, and Pending File (collectively, the “Output Files”) and performing initial and multiple subsequent iterations of deposit insurance calculations.

The compliance testing framework will be made available once the FDIC has developed sufficient understanding of CI system capabilities and limitations. Compliance testing procedures will include but not be limited to:

Verification of depositor data against the books and records of the CI, Reconciliation of the deposit account balances to the general ledger, Calculation check of insured and uninsured amounts, Reconciliation of insured, uninsured and pending balances to the deposit systems, Validating accuracy of subsequent iterations of the deposit insurance calculation, and For accounts eligible for pass-through deposit insurance where ultimate account ownership data is not

held on CI systems, processing of test data to simulate integration and processing of information received from third-parties containing underlying account information.


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2.3.3 Bank Failure

A bank failure is a closing of a bank by a federal or state banking agency. The bank is typically closed when it becomes critically undercapitalized or is unable to meet its obligations to depositors or others.


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2.4 High-Level Process

The diagram below provides an end-to-end view of the process steps that will be undertaken by the FDIC, utilizing CI data and systems, to calculate and determine insurance for the CI’s deposits, obtain associated control reports, and to perform quality checks that provide assurance.

The rectangular boxes in the diagram below represent each process step. The document boxes represent Output Files and control and summary reports that would be generated.

Covered Institution

Failure

Run End of Day Processing and

Take Snap Shot of Deposit Systems

Identify Deposit Accounts and Validate Data

Calculate and Apply Deposit

Insurance

Generate Output Files and

Summary Reports

General Ledger to Deposit Systems Reconciliation

Reconciliation between Output Files & Deposit System Snapshot

24 Hours After Closing

Allocate Pending Accounts to

Agents

Gather Required Information for

Pending Accounts

Update Bank Systems

Review and Approve Updates

from Agents

Recalculate and Apply Deposit

Insurance

Generate Output Files

24 Hours Post Close to last Account Processing

Reports

File

File

File

File

Customer File

Account File

Account Participant File

Pending File

Reports

File Pending File

Reports

File

File

File

File

Customer File

Account File


Pending File

Reconciliation between Output Files & Deposit System Snapshot

Reports

1 2 3 4 5 6 7 8 9 10

Summary Reports:- Ad-hoc reporting capabilities

Reports

Summary Reports:- Account Summary Reports- Ad-hoc reporting capabilities

Reports

Summary Reports:- Ad-hoc reporting capabilities

Reports

Summary Reports:- Account Summary Reports- Ad-hoc reporting capabilities

3.1 Deposit Insurance Determination 3.2 Pending File (Input, Process, and Output)


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Process steps 1-4 represent the first 24 hours after closing: Within the first 24 hours after the failed CI’s closing, the FDIC, using CI systems and data, undertakes a number of steps to ensure a baseline deposit insurance calculation can be established and liquidity can be quickly provided to depositors. Specifically, the following capabilities are required of the CI systems:

1. Generate deposit account balances as of the end-of-day on the day of failure. Generate snapshot of end-

of-day deposits for deposit insurance calculation purposes.

2. Identify insured deposits within each ORC at the CI.

3. Aggregate depositor account and balance data and use that data to perform the deposit insurance

calculation.

4. Generate the Output Files.

Process steps 5-10 represent the second 24 hours after closing: After the initial 24 hour period following closing, the CI’s systems will be leveraged by the FDIC to process outstanding accounts subject to the alternative recordkeeping provision and other pending accounts. As such, the following capabilities are required:

5. Assign accounts on the Pending File to FDIC agents by product type, pending reason, ORC, etc.

6. Track progress against workload and volume of pending accounts.

7. Update data attributes in the Pending File without entering adjustments into core banking systems.

8. Review and approve updates to pending accounts with information provided by third-party intermediaries

holding depositor data for pass-through insurance eligible accounts.

9. Recalculate depositor account and balance data from the Pending File and use that data to perform the

deposit insurance determination.

10. Generate the Output Files.


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2.5 Conceptual Systems Flow

Part 370 provides the CI with three years to design and implement a deposit insurance calculation system. This Information Technology Functional Guide does not prescribe the design of the systems that the CI must develop to meet the requirements. Each CI’s system will likely be unique in architecture, complexity, and capabilities, and, as such, CIs may have different methods for implementation.

The following conceptual systems flow diagram depicts how a CI with multiple deposit systems might design a system to conduct deposit insurance calculations. The chart depicts a conceptual IT infrastructure and deposit insurance calculation engine that takes inputs from all deposit systems:

1. Deposit System and Customer Information System: The CI’s system that consolidates customer account

information and combines it with basic demographic information to create a current snapshot of a

customer relationship.

2. Data Transfer: Data movement that describes the process by which data is transferred from various

source systems at the CI as outlined in Section 6.1 of this document.

3. Deposit Calculation Algorithm/Program: Program that will provide deposit calculation algorithm and

program as outlined in Section 4 of this document.

4. Deposit Calculation Storage: Repository that takes inputs from all deposit systems and stores

information. The CI will use the information ensure that data transformation and calculation processes

are identified, documented, and tested to determine deposit insurance calculation.

5. Output Files: Generate four files required as a part of Part 370, in line with the output file generation

requirements of section 370.3(b)(2) of Part 370 and outlined in Appendix A of this document.

Deposit System

Deposit Calculation Storage

Deposit System

Deposit System

Customer Information

System

Customer Information

SystemD

ata

Tra

nsf

er

Customer File

Account File


Pending File

Deposit Calculation Algorithm/Program

Da

ta T

ran

sfe

r1

2

3

5

4


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3 Process Requirements

The deposit insurance calculation process is predicated on certain fundamental processes that all CIs are currently capable of executing. These processes include timely end-of-day processing, accurate calculation of end-of-day principal and interest-earned amounts, application of full and partial holds on all accounts, daily reconciliation to the general ledger, tax reporting, timely review and application of holds, and identification of outstanding official items. These fundamental processes are outside of the scope of Part 370 and are assumed to be fully functional as part of the CI’s current business processes. Part 370 requires that a CI develop the following capabilities within three years after the effective date of Part 370. At the time of failure, the CI’s IT system must be able to complete the deposit insurance calculation process within 24 hours. The FDIC would use these capabilities to make deposit insurance determinations only after the failure of a CI.

1

3.1 Deposit Insurance Determination

1 If an account owner’s aggregate balance at a CI is no more than $250,000, assuming all accounts have been processed, then

all the funds the account owner has at a CI are fully insured and do not require an insurance determination.

Covered Institution Failure

Run End of Day Processing and

Take Snap Shot of Deposit Systems

Identify Deposit Accounts and Validate Data

Calculate and Apply Deposit

Insurance

Generate Output Files and

Summary Reports

24 Hours After Closing

1 2 3 4

Execute End of Day Processes

Obtain Snapshot of Deposit Systems

1.1

1.2

Validate Customer Information

Validate Account Information

Validate Parties to Account

Information

2.1

2.2

2.3

Pre-Insurance Determination

Calculate Insurance

3.1

3.2

Produce Control Reports


Produce Summary Reports

4.1

4.2

4.3

Apply Insured and Uninsured Amounts

3.3

Freeze Deposit Accounts

1.3


2.4

3.1 Deposit Insurance Determination


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Step 1: Run End-of-Day Processing and Take Snapshot of Deposit Systems

Major Activity: To execute the end-of-day processing on the CI’s systems post-failure to ensure baseline depositor data records and balances exist to undertake a deposit insurance calculation and, ultimately, a deposit insurance determination by the FDIC.

Key Inputs Key Outputs

— N/A — Baseline for Deposit Insurance — Snapshot of Bank’s Deposit Systems and Records

Key Steps: The following activities are conducted by the FDIC to ensure that a baseline and snapshot can be taken of the CI’s deposit systems.

Execute End-of-Day Processes: Execute the end-of-day processes to ensure that all pending transactions are

applied to the deposit systems and all balances reconcile with the general ledger. The complete minimum

requirements are detailed in 12 CFR § 360.8 Method for determining deposit and other liability account

balances at a failed insured depository institution. [https://www.fdic.gov/regulations/laws/rules/2000-

7800.html#fdic2000part360.8]

Obtain Snapshot of Deposit Systems: Obtain a snapshot of all deposit systems and customer file

systems that contain information pertinent to the deposit insurance calculations and/or remitting

insurance payments to the depositor.

Restrict Access to Deposit Accounts: Restrict access to all deposit accounts in the core banking

systems to ensure no changes can be applied to ownership or access to the account and any balance

or accrued interest.

Step 2: Identify Deposit Accounts and Validate Data

Major Activity: Segregate deposit accounts that are eligible for deposit insurance and accounts that are not eligible for deposit insurance and validate that the required information is present on deposit accounts to perform an insurance determination.


— Baseline for Deposit Insurance — Snapshot of Bank’s Deposit Systems and Records — Third Party Data Sets (as required)

— Accounts for Deposit Insurance Identified and Information Validated

— General Ledger Reconciled with Deposit Systems

Key Steps: The FDIC will conduct the following activities on the CI system to ensure deposit accounts are eligible for insurance determination.

Validate Customer Information: Validate all customer information needed for insurance

determination is present and execute the following key steps:

— Identify that customer account is eligible for Deposit Insurance under 12 CFR § 330 Deposit

Insurance Coverage [https://www.fdic.gov/regulations/laws/rules/2000-5400.html]

— Identify a unique set of customers, including removing and/or merging any duplicative

customers into a single customer record as required

— Identify that all customer information has been captured to determine insurance

— Identify customers requiring additional information

— Identify customers who have outstanding debts with the CI

— Identify government customers who have security pledged to them as a part of their deposit

agreement with the CI


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— Execute data quality controls on the customer data as outlined in Section 6.2 of this document

to determine any data quality gaps/known issues

Validate Account Information: Validate the information required to populate the Account File and

any special flags. These include but are not limited to:

— Identify any accounts that are covered under the alternative recordkeeping requirements as

outlined in Section 370.4 (b) of Part 370

[https://www.federalregister.gov/documents/2016/12/05/2016-28396/recordkeeping-for-

timely-deposit-insurance-determination]

— Identify whether any of the alternative recordkeeping accounts have transactional features

— Identify whether the accounts are associated with prepaid cards

— Identify whether accounts are pass-through accounts (i.e., those accounts held by fiduciaries,

agents, and brokers on behalf of the customer)

— Validate that each account has at least one customer associated with it (i.e., there are no

orphan accounts)

— Execute data quality controls on the account data as outlined in Section 6.2 of this document to

determine any data quality gaps/known issues

Validate Account Participant Information: Validate that the CI has captured all information for all

parties to accounts. These include but are not limited to:

— Identify unique sets of account participant records, including removing and/or merging any

duplicative participants into a single record as required

— Validate that each participant record is associated to at least one account (i.e., there are no

orphan account parties)

Produce Control Reports: Generate control reports and validate that the total account population

considered for insurance determination matches the total number of accounts in the general ledger.

The CI systems should be capable of generating the control reports outlined in Section 6.3 of this

document.

Step 3: Calculate and Apply Deposit Insurance Rules

Major Activity: Aggregate depositor accounts for all ORCs by owner and apply deposit insurance rules to all eligible deposit accounts held at the CI.


— Accounts for Deposit Insurance Identified and Information Validated

— General Ledger Reconciled with Deposit Systems

— Deposit Insurance Determination — Allocation of Insured and Uninsured

Balance Among Owners

Key Steps: The following activities are conducted by the CI system to calculate deposit insurance and used by the FDIC to determine deposit insurance.

Pre-Insurance Determination: Identify pre-insurance determination under the Deposit Insurance

Determination as outlined in Section 4.1 of this document.

Calculate Insurance: Calculate insurance under the Deposit Insurance Determination as outlined in

Section 4.2 of this document.

Apply insured and uninsured amounts: Allocate insured and uninsured balance among account

owners as outlined in Section 4.3 of this document.


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Step 4: Generate Output Files and Summary Reports

Major Activity: Generate Output Files that will act as the permanent record of the insurance determination for the customers at time of closing, including accounts in a pending status. In addition to the permanent record, additional control and summary reports will be produced to verify accuracy and completeness of the determination.


— Deposit Insurance Determination — Allocation of insured and uninsured balance among

owners

— Customer File — Account File — Account Participant File — Pending File — Summary Reports — Control Reports

Key Steps: The following activities are conducted by the CI system and utilized by the FDIC.

Generate Output File: Generate four files required as a part of Part 370, in line with the Output File

generation requirements in Section 4 of this document and outlined in Appendix A. The four key files

are:

— Customer File: The Customer File is used by the FDIC to capture information regarding the

account owners

— Account File: The Account File specifies the insured and uninsured balances available to each

account

— Account Participant File: The Account Participant File identifies account participants, captures

indicative information, and captures account participant allocations

— Pending File: The Pending File captures accounts that require additional information before a

deposit insurance determination can be completed


considered for the insurance determination matches the total number of accounts in the account

and Pending Files. The CI system should generate the control reports outlined in Section 6.3 of this

document.

Produce Summary Reports: Generate the summary reports required by the FDIC and the CI that

highlight the total account allocations by various dimensions. The details of the specific account

summary reports required are outlined in Section 7 of this document.


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3.2 Pending File (Input, Process, and Output)

The Pending File captures accounts that require additional information before a deposit insurance determination can be completed. The Pending File contains available account information and may be used to contact the account owner or to request additional information needed to complete the deposit insurance calculation.

The procedures that the CI systems should be able to follow to process additional information are documented below:

Step 5: Allocate Pending Accounts to Agents

Major Activity: Assign pending accounts by product type, pending reason, ownership right and capacity, etc., to FDIC agents.


— Pending File — Summary Reports

— Allocation of pending accounts to agents

Key Steps: The following activities are conducted by the CI system and utilized by the FDIC to ensure that pending accounts are allocated to FDIC agents.

Assign Pending Accounts to Agents: Assign accounts to FDIC claims agents that specialize in a

pending reason code or account type and balance workload across FDIC claims agents.

— The CI to demonstrate that it has a system of tracking and assigning accounts generated in the

Pending File by product type, pending reason, ownership right and capacity, etc.

— The CI to establish the ability to track progress against workload and volume of pending

accounts

Allocate Pending Accounts to

Agents

Gather Required Information for

Pending Accounts

Update Bank Systems

Review and Approve Updates

from Agents

Recalculate and Apply Deposit

Insurance


24 Hours Post Close to last Account Processing

5 6 7 8 9 10


Generate Output File

Produce Summary Reports

10.1

10.2

10.3

Determine Approval Method

8.1

Assign Pending Accounts to

Agents

Capture Information for Broker Accounts

Capture Information for Non-Broker AR

Accounts

Manual Update

Automated Update

Manual Approval

Automated Approval

5.1

6.2

6.3

7.1

7.2 8.2

8.3

Capture Information for Bank Customer

Accounts

6.1

Match and Merge Records

7.3

Pre-Insurance Determination

Calculate Insurance

9.1

9.2

Apply Insured and Uninsured Amounts

9.3

3.2 Pending File (Input, Process, and Output)


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Step 6: Gather Required Information for Pending Accounts

Major Activity: Conduct outreach to gather and capture information needed to complete the deposit insurance determination.


— Allocation of pending accounts to agents — Captured Information to be updated

Key Steps: The following activities are conducted by CI systems and utilized by the FDIC in order to capture data needed to complete the deposit insurance determination.

Capture Information for Bank Customer Accounts: Update all aspects of the account that will be

used to determine insurance.

— The CI system to capture all outbound information provided by the customer

Capture Information for Broker Accounts: Update all aspects of the broker account that will be used

to determine insurance.

— The FDIC to contact the broker for information on pending accounts

— The FDIC to anticipate the broker communicating via a flat file which can be loaded into the CI’s

system

Capture Information for Non-Broker Alternative Record Keeping Accounts: Update all aspects of

these accounts, which will be used by:

— The FDIC to contact the third party for information on accounts

— The FDIC to anticipate the third party communicating via a flat file which can be loaded into the

CI’s system

Step 7: Update Bank Systems

Major Activity: Update the information provided by customers, brokers, and third parties into the CI’s systems for the purposes of calculating deposit insurance.


— Captured Information to-be Updated — Updated Customer and Account Information — Supporting Documentation — Audit Log of Changes

Key Steps: The following activities are conducted by the CI systems and utilized by the FDIC to update bank systems.

Manual Update: Manual upload/type of information provided by customers directly into a data

capture system. Importantly, the CI system is required to:

— Provide the capability for an FDIC claims agent to manually update all data elements required to

support the recalculation of deposit insurance

— Provide the capability to attach additional documentation, such as electronic trust documents,

declarations to support any updates

— Assess the quality and completeness of the data provided by the customer in line with its

internal data quality requirements

— Track the updates made to each element by a user, including the old and new values and the

date and time of the update


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Automated Update: Upload of information provided by brokers or third parties directly into a data

capture system. Importantly, the CI system is required to:

— Provide the capability for an automated file load to update all data elements required to

support the recalculation of deposit insurance, in line with the agreed broker and third-party

data exchange formats

— Assess the quality and completeness of the data provided by the third parties in line with their

internal data quality requirements

— Provide the capability for any erroneous load of data to be either rolled back in full or manually

adjusted and reprocessed

— Track the updates made to each element and record by the automated file import, including the

old and new values and the date and time of the update

— Maintain a static read only copy of the file that was updated successfully for audit purposes

Match and Merge Customers/Account Participant Records: Once the data has been loaded into the

system, the CI system should have capability to:

— Match and merge any new customer records provided within the existing customer records held

by the CI

— Match and merge any new account participant records provided within the existing account

participant records held by the CI

The CI is responsible for the development of any matching rules, and the CI will apply matching rules in line with Anti-Money Laundering and Know Your Customer rules.

Step 8: Review and Approve Updates

Major Activity: The deemed approver at the FDIC reviews and approves updates from FDIC claims agents that are providing information for pending accounts.


— Updated Customer and Account Information — Supporting Documentation — Audit Log of Changes

— Approval or Rejection of Account Updates — Updated Information ready for Insurance

Determination

Key Steps: The following activities are conducted by the CI systems and utilized by the FDIC to ensure that information input into CI systems is validated and approved.

Determine Approval Method: Route the approval of the update to either the manual or automated

approval methods. To enable this capability the CI is required to:

— Provide the capability to segment approval channel by ORC, product type, total account value,

total insured amount, and other factors

— Provide the capability for multi-level approvals, allowing for at least two tiers of approvals. The

determination of the tiers should be driven based on the same attributes above

— Provide approver access to all accounts owned by unique depositor

Manual Approval: If a manual approval is required based on a set of metrics (e.g., account balance,

insured amount, etc.), the CI system must be able to:

— Allocate the record to the correct approver, based on the approval matrix noted above

— The manual approver must be able to review attachments from the FDIC resolution agent. The

needed information on what modification was done and the supporting information for the

modification


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— The manual approver must be able to approve and reject records. It is expected that a standard

list will be created by the CI in its systems, but, at a minimum, two categories, “More

Information Required” and “Disagree with Assessment,” are expected

Automated Approval: If no manual approval is required, execute automated approval if permissible

based on a set of metrics (e.g., account balance, insured amount, etc.).

Step 9: Recalculate and Apply Deposit Insurance

Major Activity: Aggregate depositor accounts for all ORCs, and perform and apply deposit insurance rules to all eligible deposit accounts held at the CI.


— Approval or Rejection of Account Updates — Updated Information Ready for Insurance

Determination

— Updated Deposit Insurance Determination — Allocation of Insured / Uninsured Amounts by

Accounts

Key Steps: The following activities are conducted by the CI systems utilized by the FDIC to calculate and determine deposit insurance.

Pre-Insurance Determination: Identify pre-insurance determination under the Deposit Insurance

Determination as outlined in Section 4.1 of this document.

Calculate Insurance: Recalculate insurance under the Deposit Insurance Determination as outlined

in Section 4.2 of this document.

Apply Insured and Uninsured Amounts: Allocate insured and uninsured balance among account

owners under the Deposit Insurance Determination as outlined in Section 4.3 of this document.

Step 10: Generate Output Files

Major Activity: Following the recalculation of deposit insurance, the CI system will regenerate all the Output Files that will act as the permanent record of the deposit insurance determination. Importantly, the requirement is to regenerate the files in full, and not only to produce the variances that have been updated. In addition to the permanent record, the CI’s system is required to generate the control and summary reports that will verify accuracy and completeness of the determination.


— Updated Deposit Insurance Determination — Allocation of Insured / Uninsured Amounts by

Accounts

— Customer File — Account File — Account Participant File — Pending File — Summary Reports — Control Reports

Key Steps: The following activities are conducted by the CI system and utilized by the FDIC to ensure that Output Files are generated.

Generate Output File: Regenerate four files required as a part of Part 370, in line with the Output

File creation details in Section 4 of this document and outlined in Appendix A. The four key files are:

— Customer File: The Customer File is used by the FDIC to capture indicative information regarding

the Account owners


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— Account File: The Account File specifies the insured and uninsured balances available to each

account

— Account Participant File: The Account Participant File identifies account participants, captures

indicative information, and captures account participant allocations.

— Pending File: The Pending File captures accounts that require additional information before a

deposit insurance determination can be completed.


considered for insurance determination matches the total value of accounts in the account and

Pending Files. The CI system should generate the control reports outlined in Section 6.3 of this

document that will confirm that baseline data reconciles with final output of all accounts.

Produce Summary Reports: Generate the summary reports required by the FDIC and the CI that

highlight the total account allocations by various dimensions. The details of the specific account

summary reports required are outlined in Section 7 of this document.


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4 Deposit Insurance Determination Requirements

In the event that a CI fails, the following process must be followed to accurately identify each account’s right and capacity for its owner(s) and determine the deposit insurance coverage for each account/account owner. References to actions to be taken by a CI and/or its systems after the FDIC has been appointed receiver are intended to be taken at the direction of or on the behalf of the FDIC in its receivership capacity, as applicable. The CI’s systems must be able to:

1) Identify each account and its owner(s) and determine if the CI has enough information for making a deposit insurance determination for each account/account owner within 24 hours of bank failure.

2) Make the right and capacity determination for each account/account owner and determine the deposit insurance coverage for the account/account owner based on the right and capacity and the deposit insurance calculation rules described in the following sections for accounts in that right and capacity.

3) Apply insured and uninsured funds determined in capability number 2 above.

The following sections describe the process necessary for completing meeting capabilities 1-3 above. Accounts should be processed in the manner described in Sections 4.1 through 4.3 below (these processes are intended to be performed in sequential order, beginning with Section 4.1).

Note, for purposes of this document, the right and capacity determination and the deposit insurance calculation processes have been documented by right and capacity. Please refer to the corresponding segment of Section 4.2 below for details of these two processes.

4.1 Initial Processing

4.1.1 Overview

This section outlines the initial processing steps that must be performed on an account before making an insurance determination. Before making an insurance determination, the CI must identify if the necessary account information is known, if an account belongs to recently merged IDIs, and if an account is a fiduciary account.

4.1.2 Identification of Account Information

1) If the CI lacks sufficient information for identifying account owner(s), beneficiary, or fiduciary (e.g., trustee, agent, custodian), then place the account in the Pending File (see Section 5.4 of this document).

2) For an account for which an account owner is identified:

a) If the account lacks sufficient information for purposes of calculating the deposit insurance coverage, then place the account and the account owner in the Pending File (see Section 5.4 of this document)

4.1.3 Merger of IDIs

If there is a recent merger of two IDIs, then the CI may be required to separately calculate deposit insurance and generate a separate set of Output Files (one from the acquired IDI and the other from the acquiring IDI. If the account does not belong to a recently merged IDI (more than six months prior to the CI failure) or if the depositor only holds funds at one of the two IDIs that merged, then proceed to Section 4.2 of this document. 1) If there is a merger which occurred less than six months prior to CI failure, the CI calculates deposit insurance

on the accounts at each of the merged entities separately and produces a set of files for each.


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2) If the merger occurred more than six months prior to failure, the CI must:

a) Separately insure time deposits that mature after the six-month grace period until they mature and separate these accounts and produce a set of files for these accounts.

b) Separately insure time deposits that are renewed on identical terms within the first six months after the effective date of the merger until the first maturity date after the expiration of the six-month period and produce a set of files for these accounts.

c) If the above account scenarios do not exist, the CI should process all accounts in a single insurance determination and produce a single set of files.

4.1.4 Alternative Recordkeeping and Fiduciary Accounts

If an account meets FDIC’s definition of fiduciary account2:

1) If sufficient information of a principal and his ownership interest in the fiduciary account is available so that the deposit insurance coverage can be determined within 24 hours of bank failure, then place the account and the principal in the Account File.

2) If sufficient information of a principal and/or his ownership interest in the fiduciary account is not available so that the insurance determination cannot be completed within 24 hours of bank failure, then place the account and the principal in the Pending File.

3) If the account and principal are placed in the Pending File, then determine the deposit insurance coverage upon obtainment of sufficient information based on the actual right and capacity of the funds held by the principal.

4.1.5 Pre-Insurance Determination

If an account owner’s aggregate balance at a CI is no more than $250,000, then all the funds the account owner has at a CI are fully insured and do not require an insurance determination.

4.2 Right and Capacity and Deposit Insurance Determination

4.2.1 Overview

This section outlines the steps for completing the ORC, SMDIA, and deposit insurance determinations on accounts. For purposes of this document, the ORC, SMDIA, and deposit insurance determinations have been grouped by right and capacity. The ORC determination for each account/account owner must be made first. After the ORC determination has been made, follow the procedures outlined below for accounts in each ORC to make deposit insurance determination for each account/account owner.

4.2.2 Single Accounts

4.2.2.1 Right and Capacity and SMDIA Determination

Determine if account meets FDIC requirements for a single account:

1) Identify account owner(s).3

2) If there are multiple account owners, refer to section 4.2.3 of this document for Joint Accounts.

2 Fiduciary accounts are deposit accounts established by a person or entity (the fiduciary) for the benefit of one or more parties,

also known as principals. Fiduciary accounts are not insured as a separate ORC and the deposit insurance coverage for such accounts depends on the actual ORC in which the principal or owner holds the funds. As a result, fiduciary accounts are added to the principal’s other accounts in the same ORC at the same CI for purpose of a deposit insurance determination. 3 Account owner shall be deemed as a depositor entitled to up to the SMDIA as provided for under the applicable ownership

category.


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3) If the account owner has designated eligible beneficiaries, then refer to Section 4.2.4 or Section 4.2.5 of this document for either revocable or irrevocable trust accounts.

4) If the account is a self-directed retirement plan account, then refer to Section 4.2.6 of this document for Certain Retirement Accounts.

5) If an account owner is deceased, then:

a) If within six months of the death of the account owner, then the decedent should be treated as though he or she were still alive, assuming no change to the titling of the account and this treatment benefits the depositor.

b) If the account owner has been deceased for more than six months, then calculate deposit insurance based on the actual ownership.

c) If the deceased is the sole owner of the single account, funds in all single accounts held by the deceased owner at the CI is insured up to SMDIA.

6) If an account meets the definition of a single account (see Appendix B), then set DP_Right_Capacity equal to SGL.

7) The account owner of a single account for the combined amount of his or her interests in all single accounts at the same CI is entitled to SMDIA.

4.2.2.2 Single Account Deposit Insurance Calculation

If all single accounts have been processed through Section 4.2.2.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then:

1) Identify all single account owners.

2) Aggregate total account balance and accrued interest by each unique account owner for all accounts held by the owner in the single account right and capacity at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) For the aggregated account balance and accrued interest for each account owner:

a) If the total balance and accrued interest does not exceed SMDIA, then the funds are fully insured and the insured amount for each account is equal to the sum of balance and accrued interest.

b) If the total balance and accrued interest exceeds SMDIA, then funds in excess of SMDIA are not insured.

4) If there are uninsured funds for the account owner, then:

a) Apply the uninsured amount first to the accrued interest (if any) of each account.

b) If there is an uninsured amount remaining after step 4 (a), determine the owner’s single account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

c) If after step 4 (b), there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.

d) If after step 4 (c), there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

5) Based on the above determination, determine and record the respective uninsured amount to each account for the account owner.

6) Determine the insured amount for each individual account as the sum of current balance and accrued interest, less the uninsured amount and record the insured amount for each account.

7) Flag accounts that have been processed as an insurance determination is completed.


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4.2.3 Joint Accounts


Determine if account meets FDIC requirements for a joint account:

1) Identify all co-owners of the account and their withdrawal rights.

2) If withdrawal rights are unequal across all co-owners, then refer to Section 4.2.2 of this document for Single Accounts.

3) If an account co-owner is deceased, then:

a) If within six months of the death of the account co-owner, the decedent should be treated as though he or she were still alive, assuming no change to the titling of the account.

b) If the account co-owner has been deceased for more than six months, the decedent is not considered an account co-owner. As a result, calculating deposit insurance based on the actual ownership may cause funds to revert from the joint account category to the single account category if there are no longer multiple account owners. Please refer to Section 4.2.2 of this document for SMDIA Determination for details on the determination for the single account category.

4) If account meets the definition of a joint account (see Appendix B), then set DP_Right_Capacity equal to JNT.

5) Split the total account balance and accrued interest equally across the total number of account co-owners.

6) Each co-owner of a joint account for their combined amount of his or her interests in all joint accounts at the same CI is entitled to SMDIA.

7) EACH DEPOSITOR IS ENTITLED TO INSURANCE UP TO THE SMDIA IN EACH ORC. DUE TO THE JOINT OWNERSHIP NATURE OF THIS ORC, EACH DEPOSITOR IS SUBJECT TO DEPOSIT INSURANCE COVERAGE LIMITS ON AN INDIVIDUAL BASIS BUT THE DEBITS ARE APPLIED ON AN ACCOUNT LEVEL.

4.2.3.2 Joint Account Deposit Insurance Calculation

If all joint accounts have been processed through Section 4.2.3.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then:

1) Identify all unique joint account co-owners.

2) Aggregate total account balance and accrued interest for each unique account owner for those accounts held in the JNT right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).


a) If the total balance and accrued interest of an account owner does not exceed SMDIA, then the funds of the account owner across all joint accounts at the CI are fully insured.

b) If the total balance and accrued interest of an account owner exceeds SMDIA, then the owner’s funds in excess of SMDIA are not insured. If there are uninsured funds, then:

c) Determine the uninsured amount for each account owner based on steps 3(a) and 3(b) above.

4) If there is an uninsured amount for an account owner:

a) Determine the allocation ratio for each owner with uninsured funds by dividing the owner’s uninsured amount by the owner’s aggregate total balance.

b) Apply the uninsured amount first to the accrued interest (if any) of all such accounts.

c) If there is an uninsured amount remaining after step 4(b), allocate remaining uninsured funds of each owner based on the allocation ratio calculated above across all such accounts.


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5) Based on the above determination (and repeat as necessary for each account owner), determine and record the respective uninsured amount for each account of the account owner.

6) The insured amount of the owner for each individual account is the difference between the owner’s funds in that account and the uninsured amount determined based on the steps above.

7) Flag the owner’s accounts that have been processed as an insurance determination is completed.

4.2.4 Revocable Trust Accounts


Determine if account meets FDIC requirements for a revocable trust account:

1) Identify all account owner(s) and all unique primary beneficiaries.

a) A beneficiary is a primary beneficiary if his or her interest in the trust does not depend on the death of another trust beneficiary.


a) If within six months of the death of the account owner, the decedent should be treated as though he or she were still alive, assuming no change to the titling of the account.

b) If the account owner has been deceased for more than six months, the decedent is not considered an account owner. Instead, the estate of the decedent is considered the actual owner of the account. As a result, calculate the deposit insurance by treating the estate of the decedent as the account owner.

3) Identify eligible unique primary beneficiaries.

a) If a primary beneficiary is deceased, then:

i) If there is no substitute or contingent beneficiary named in the revocable trust document for that primary beneficiary, then the beneficiary should be ignored for purposes of deposit insurance calculation.

(1) Funds associated with that primary beneficiary should be treated as funds in a single or joint account ORC belonging to the trust account owner(s) and aggregated and insured with other accounts of the trust account owner(s) in the corresponding ORC.

ii) If the trust document indicates the interest associated with the deceased primary beneficiary is passed to other beneficiaries (e.g., per stirpes

4 or per capita), determine the eligibility of the

successor beneficiaries and the total number of unique eligible beneficiaries (including eligible successor beneficiaries) for purposes of deposit insurance determination.

b) For Payable-on death (POD) revocable trust account.

i) If a beneficiary is ineligible,5 then the beneficiary should be ignored for purposes of deposit insurance

calculation for the revocable trust account(s) of the account owner at the CI.

(1) Funds associated with that ineligible beneficiary should be treated as funds in a single or joint account right and capacity belonging to the trust account owner(s) and aggregated with other accounts the trust account owner(s) have under the corresponding right and capacity.

4 Per stirpes implies the estate of the deceased primary beneficiary is to be distributed to each branch of the family in equal

share. 5 An ineligible beneficiary does not meet the requirements of an eligible beneficiary but is still able to legally receive the

bequest under state law. Examples of ineligible beneficiaries include for-profit business entities and pet trusts. For purposes of calculating deposit insurance coverage, the funds associated with an ineligible beneficiary is reverted to funds in either the single or joint right and capacity of the grantor(s).


Page | 23

c) For formal revocable trust account.

i) If a beneficiary is deceased or ineligible, review the trust document to determine the actual allocation of the funds associated with that beneficiary and determine the total number of unique eligible beneficiaries (including eligible successor beneficiaries) for purposes of deposit insurance calculation.

d) If a primary beneficiary is invalid.6

i) Funds associated with that invalid beneficiary should be allocated to the remaining beneficiaries.

e) If the account owner or co-owners are the sole beneficiaries of the corresponding trust, then identify the account as a single or joint account depending on the account owner(s) (see Section 4.2.2 or Section 4.2.3 of this document for Single or Joint Accounts depending on the actual owner(s)).

f) If the account names as beneficiary a formal revocable trust owned in whole or part by someone other than the account owner(s), then refer to Section 4.2.2 or Section 4.2.3 of this document for Single or Joint Accounts representing the interest of the owner(s).

g) If the account has no eligible beneficiaries, then refer to Section 4.2.2 or Section 4.2.3 of this document for Single or Joint Accounts depending on the account owner(s).

4) If the account meets the definition of a revocable trust account (see Appendix B), then set DP_Right_Capacity equal to REV.

5) Identify information related to allocation of funds to eligible unique primary beneficiaries.

a) If ownership allocations to beneficiaries are not stated for a POD account, then assume an equal allocation across all beneficiaries.

b) If ownership allocations to beneficiaries are not stated for a revocable trust account other than a POD account, then place the account in the Pending File (see Section 5.4 of this document).

6) If account owner information or beneficiary information is not complete, then place the account in the Pending File (see Section 5.4 of this document).

7) If there is a life estate beneficiary who has the right to receive income from the trust or to use trust assets during the beneficiary’s lifetime prior to other beneficiaries, then flag the beneficiary as a life estate beneficiary.

8) Each unique combination of account owner and unique life estate beneficiary is entitled to SMDIA for the combined amount of all account interests at the same CI.

9) Each unique combination of account owner and eligible unique primary beneficiary is entitled to SMDIA for the combined amount of all account interests at the same CI.

4.2.4.2 Revocable Trust Account Deposit Insurance Calculation

If all revocable trust accounts have been processed through Section 4.2.4.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then complete the following steps in order:

1) Identify the account owners and unique primary beneficiaries.

2) For each account owner identify the associated eligible unique primary beneficiaries.

6 An invalid beneficiary is unable to legally receive the bequest under state law. Example of invalid beneficiaries include a

fictional person or any entity that does not meet requirements of an eligible beneficiary and is not eligible to receive the bequest under state law. For purposes of calculating deposit insurance coverage, bequests to invalid beneficiaries are ignored and funds are allocated to the remaining beneficiaries.


Page | 24

3) Determine the allocations to the eligible unique primary beneficiaries based on the information of the allocation of funds (note a life estate beneficiary is valued at $250,000 for purpose of deposit insurance determination).

4) Determine the aggregate funds each account owner has across all revocable trust accounts at the CI allocated to eligible unique primary beneficiaries. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

5) If the total number of eligible unique beneficiaries of an account owner is five or fewer or if all primary beneficiaries have equal interest in the owner’s trust account (regardless of the total number of beneficiaries), then:

a) If the total amount of the owner’s interest does not exceed SMDIA times the number of eligible unique beneficiaries, then the owner’s entire revocable trust funds at the CI are fully insured.

b) If the total amount of the owner’s interest is greater than SMDIA times the number of eligible unique beneficiaries, then the excess is the uninsured amount for the account owner.

6) If the total number of eligible unique beneficiaries of an account owner is six or more and all the beneficiaries do not have equal interest in the trust, then:

a) Determine the insured and uninsured amount for the funds associated with each beneficiary based on the aggregate dollar allocation from each account owner to each eligible unique beneficiary as determined above in Step 3 by following the rules below:

i) If the actual allocation to each beneficiary is $250,000 or less, then the account owner’s entire revocable trust funds are fully insured.

ii) If the owner’s trust account contains life estate beneficiaries, then the interest for each unique life estate beneficiary is insured up to SMDIA.

iii) If any beneficiary interest exceeds SMDIA, then the owner is insured for the greater of (a) the sum of each beneficiary’s share of the trust deposit up to SMDIA for each beneficiary or (b) $1,250,000.

b) If the total amount of the owner exceeds the insured amount determined based on the above, the excess is the uninsured amount for the owner.

7) For funds the owner has in an ORC other than REV, aggregate the funds the owner has at the CI across all accounts under that ORC (if necessary) and determine the deposit insurance based on the algorithm prescribed for that ORC.

8) If there are uninsured funds for the owner in either the REV or other ORC, then:


b) If there is an uninsured amount remaining after step 8(a), determine the owner’s account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

c) If after step 8(b), there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.

d) If after step 8(c), there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

9) Based on the above determination, determine and record the respective uninsured amount of the owner to each associated account.

10) The insured amount of the owner for each associated account is the difference between the owner’s interests in that account and the uninsured amount determined based on the steps above.



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4.2.5 Irrevocable Trust Accounts


Determine if account meets FDIC requirements for an irrevocable trust account:

1) Identify all grantor(s) and all unique primary beneficiaries.

a) A beneficiary is a primary beneficiary if his or her interest in the irrevocable trust does not depend on the death of another trust beneficiary.

2) If an account became an irrevocable trust account due to the death of an owner of a revocable trust account, then refer to Section 4.2.4 of this document for Revocable Trust Accounts.

3) If an account is a trust account where the account owner has not relinquished control of the funds, then refer to Section 4.2.4 of this document for Revocable Trust Accounts.


a) If within six months of the death of the account owner, the decedent should be treated as though he or she were still alive, assuming no change to the titling of the account.

b) If the account owner has been deceased for more than six months, the decedent is not considered an account owner. As a result, calculate deposit insurance based on the actual owner(s).

5) If a primary beneficiary is deceased, then:

a) If there is no substitute or contingent beneficiary named in the irrevocable trust document for that primary beneficiary, the beneficiary should be ignored for purposes of deposit insurance calculation.

i) Funds associated with that primary beneficiary should be treated as funds in a single or joint account right and capacity belonging to the trust account owner(s) and aggregated and insured with other accounts of the trust account owner(s) have in the corresponding right and capacity.

b) If the irrevocable trust document indicates the interest associated with the deceased primary beneficiary is passed to other beneficiaries (e.g., per stirpes

7 or per capita), determine the eligibility of the successor

beneficiaries and the total number of unique eligible beneficiaries (including eligible successor beneficiaries) for purpose of deposit insurance determination.

6) If a beneficiary is ineligible,8 then:

a) The beneficiary should be ignored for purposes of deposit insurance calculation and funds associated with that ineligible beneficiary should be treated as funds in a single or joint account right and capacity belonging to the trust account owner(s) and aggregated with other accounts the trust account owner(s) have under the corresponding ORC.

7) If a beneficiary is invalid,9 then:

a) Funds associated with that invalid beneficiary should be allocated to the remaining beneficiaries.

7 Per stirpes implies the estate of the deceased primary beneficiary is to be distributed to each branch of the family in equal

share. 8 An ineligible beneficiary does not meet the requirements of an eligible beneficiary but is still able to legally receive the

bequest under state law. Examples of ineligible beneficiaries include for-profit business entities and pet trusts. For purposes of calculating deposit insurance coverage, the funds associated with an ineligible beneficiary is reverted to funds in either the single or joint right and capacity of the grantor(s). 9 An invalid beneficiary is unable to legally receive the bequest under state law. Example of invalid beneficiaries include a

fictional person or any entity that does not meet requirements of an eligible beneficiary and is not eligible to receive the bequest under state law. For purposes of calculating deposit insurance coverage, bequests to invalid beneficiaries are ignored and funds are allocated to the remaining beneficiaries.


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8) If the grantor(s) are the sole beneficiaries of the irrevocable trust, then refer to Section 4.2.2 or Section 4.2.3 of this document for Single or Joint account processing, respectively, depending on the account ownership.

9) If the account names as beneficiary an irrevocable trust owned in whole or part by someone other than the grantor(s), then refer to Section 4.2.2 or Section 4.2.3 of this document for Single or Joint account processing, respectively, depending on the account ownership.

10) If the account has no eligible beneficiaries, then refer to Section 4.2.2 or Section 4.2.3 of this document for Single or Joint account processing, respectively, depending on the account ownership.

11) If the account meets the definition of an irrevocable trust account (see Appendix B), then set DP_Right_Capacity equal to IRR.

12) Determine the allocations to beneficiaries.

a) If ownership allocations to beneficiaries are not stated, then assume an equal allocation across beneficiaries.

b) If beneficiary information or information on beneficial interests is not complete, then place the account in the Pending File (see Section 5.4 of this document).

13) If beneficiary information and beneficiary percentage share is available, then flag any funds representing a grantor’s “retained interest”

10 and undertake the following steps for remaining funds:

a) Split the total account balance and accrued interest across the grantor(s).

b) Allocate the total amount of each grantor to each eligible unique beneficiary based on the beneficiary’s percentage share.

c) Flag the beneficiary with non-contingent trust interest.11

d) Flag the beneficiary with contingent interest.12

14) Each unique combination of grantor and eligible unique beneficiary is entitled to SMDIA for the combined amount of all non-contingent trust interests

at the same CI

15) The aggregate of all contingent interests of a grantor for the irrevocable trust at the same CI is entitled to SMDIA.

16) The aggregate of all funds representing a grantor’s retained interest are insured as a single account of the grantor, combined with the grantor’s other single accounts at the CI and insured up to SMDIA (see Section 4.2.2 of this document for SMDIA Determination).

4.2.5.2 Irrevocable Trust Account Deposit Insurance Calculation

If all irrevocable trust accounts have been processed through Section 4.2.5.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then:

1) Identify all grantor(s) and all eligible unique beneficiaries.

2) Determine the non-contingent trust interest and contingent interest by the unique combination of grantor and beneficiary.

3) Determine each grantor’s retained interest if there is any.

10

“Retained Interest” represents those assets that can be returned by the trustee to the grantor in accordance with the terms of the trust agreement. 11

“Non-contingent trust interest” is defined in the FDIC’s regulations as an interest capable of determination without evaluation of contingencies other than present worth/life expectancy. 12

“Contingent interest” is a beneficiary interest that is subject to any types of contingency other than present worth/life expectancy.


Page | 27

4) Aggregate all non-contingent trust interests by grantor (if any). If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

a) If the total amount of a grantor’s non-contingent interests does not exceed SMDIA times the number of eligible unique beneficiaries, the grantor’s non-contingent interests at the CI are fully insured.

b) If the total amount of a grantor’s non-contingent interests exceeds SMDIA times the number of eligible unique beneficiaries, the grantor’s non-contingent interests at the CI are not fully insured and the excess is the uninsured amount.

5) Aggregate all contingent interests by grantor and trust (if any). If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

a) If the total contingent interest of a grantor does not exceed SMDIA, the grantor’s contingent interests at the CI are fully insured.

b) If the total contingent interest of a grantor exceeds SMDIA, the grantor’s contingent interests at the CI are not fully insured and the excess is the uninsured amount.

6) The sum of the uninsured amounts from the non-contingent trust interests and contingent interests of the grantor is the total uninsured amount of the grantor in the IRR right and capacity at the CI.

7) Aggregate each grantor’s retained interests (if any) with the grantor’s other single account interests (if any) at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

a) If the total amount does not exceed SMDIA, the grantor’s total funds in the single account right and capacity at the CI are fully insured.

b) If the total amount exceeds SMDIA, the grantor’s total funds in the single account right and capacity at the CI are not fully insured and the excess is the uninsured amount.

8) If there are uninsured funds for a grantor in the irrevocable trust ORC, then for each irrevocable trust account associated with the grantor.

a) Apply the uninsured amount first to the accrued interest (if any) of all such accounts.

b) If there is an uninsured amount remaining after step 8(a), allocate the remaining uninsured amount by following the liquidity priority order (see Section 4.2.16 of this document).


d) If post steps 8(c), there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

e) Based on the above determination, determine and record the respective uninsured amount to each irrevocable trust account associated with the grantor.

9) If there are uninsured funds for a grantor in the single account right and capacity, then for each account the grantor has at the CI in the SGL right and capacity, perform step 8 as described above to determine the uninsured amount for each account the grantor has under the SGL right and capacity.

10) For each grantor and for each ORC (IRR or SGL), the insured amount for each individual account is the difference between the funds of the account allocated to that right and capacity and the corresponding uninsured amount.

11) Flag the grantor’s accounts that have been processed as an insurance determination is completed.


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4.2.6 Certain Retirement Accounts13


Determine if account meets FDIC requirements for a certain retirement account,:

1) Identify account owner and plan administrator.

2) If account is an Education IRA,14

then refer to Section 4.2.5 of this document for Irrevocable Trust Accounts.

3) If account is defined benefit plan or defined contribution plan which is not self-directed, then refer to Section 4.2.7 of this document for Employee Benefit Plans.

4) If account owner is deceased, then: a) If account continues to be maintained in the decedent’s name and continues to be recognized as the

decedent’s certain retirement account, the account is insured as a certain retirement account of the

decedent.

b) If account ownership transferred from the decedent to another individual or entity, calculate deposit

insurance based on the actual ownership.

5) If account meets the definition of a certain retirement account (Appendix B), then set DP_Right_Capacity equal to CRA.

6) Each account owner of a certain retirement account for the combined amount his or her interest of all certain retirement accounts at the same CI is entitled to SMDIA.

4.2.6.2 Certain Retirement Account Deposit Insurance Calculation

If all certain retirement accounts have been processed through Section 4.2.6.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then:

1) Identify all certain retirement accounts by the account owner.

2) Aggregate total account balance and accrued interest by each account owner for those accounts held in the CRA ORC. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) For the aggregated account balance and accrued interest for each account owner,

a) If the total balance and accrued interest allocated to the account owner does not exceed SMDIA, then the funds are fully insured.

b) If the total balance and accrued interest allocated to the account owner does exceed SMDIA, then funds in excess of SMDIA are not insured.


a) Apply the uninsured amount first to the accrued interest of all such accounts (if any).

b) If there is an uninsured amount remaining after step 4(a), determine the owner’s CRA account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

c) If after step 4(b), there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance and accrued interest first.

13

Commonly known as Individual Retirement Accounts (IRAs) and includes other self-directed retirement accounts. 14

Coverdell Education Savings Account with designated eligible beneficiaries.


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d) If after step 4(c), there are multiple accounts with the same product type that exceed SMDIA with the same total balance and accrued interest, the CI should select an account for which to apply the uninsured amount.

5) Based on the above determination, record the uninsured amount to each account associated with the account owner.

6) The insured amount for each individual account is the difference between the sum of current balance and accrued interest and the uninsured amount.

7) Flag accounts that have been processed as insurance determination completed.

4.2.7 Employee Benefit Plan Accounts


Determine if account meets FDIC requirements for an employee benefit plan account:

1) Identify the employer, plan administrator, and types of deposit.

2) If an account is a self-directed account, then refer to Section 4.2.6 of this document for Certain Retirement Accounts.

3) If account meets the definition of an employee benefit plan account (see Appendix B), then set DP_Right_Capacity equal to EBP.

4) If there is overfunding of an employee benefit plan, then set DP_Right_Capacity equal to BUS for the overfunding and set the account owner to the employer.

5) If any funds in the account are invested in non-deposit products such as stocks, bonds, or other investments, then the insurance coverage will only apply to the funds that are on deposit at the CI.

6) Identify each of the plan participants and the share each participant has in the employee benefit plan based on the account information for the insurance calculation.

7) If the identification of the participants or their percentage share is not available, then place account in the Pending File (see Section 5.4 of this document).

8) If participant identification or their percentage share information is available, then:

a) Flag plan participants with contingent interests that are not based on age.15

b) For each participant, calculate share of total employee benefit plan.

c) If there is any residual value following the allocation to the participants, then flag the participant employee benefit plan for overfunding.

9) The aggregate of all non-contingent interests for a combination of unique employer account and unique plan participant for an employee benefit plan at the same CI is entitled to SMDIA.

16

10) The aggregate of all contingent interest for a combination of unique employer account and unique plan participant for an employee benefit plan account at the same CI is entitled to SMDIA.

11) The aggregate of all overfunding for an employer for an employee benefit plan account at the same CI is entitled to SMDIA.

15

“Contingent interest” is defined under the terms of each employee benefit plan documents 16

“Non-contingent interest” is an interest capable of determination without evaluation of contingencies other than life expectancy.


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4.2.7.2 Employee Benefit Plan Account Deposit Insurance Calculation

If all employee benefit plan accounts have been processed through Section 4.2.7.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then:

1) Identify all employee benefit plan accounts by unique employer accounts and unique plan participants.

2) Aggregate total account balance and accrued interest by each unique plan participant for all non-contingent interests. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) Aggregate total account balance and accrued interest by each unique plan participant for all contingent interests. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

4) Aggregate total account balance and accrued interest by each unique employer for all overfunding. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

5) For each of the aforementioned aggregations:

a) If the total balance and accrued interest does not exceed SMDIA, then the funds are fully insured.

b) If the total balance and accrued interest does exceed SMDIA, then funds in excess of SMDIA are not insured.

6) If there are uninsured funds for a plan participant in the EBP right and capacity, then:


b) If there is an uninsured amount remaining after step 6(a), apply the uninsured amount for each plan participant with an uninsured amount as follows:

i) Determine the allocation ratio for each plan participant with remaining uninsured funds by dividing the plan participant’s uninsured amount by the plan participant aggregate total balance calculated in steps 2 and 3, above.

ii) Allocate the remaining uninsured amount for the plan participant based on the allocation ratio calculated in step6(b)( i).

iii) Determine the total uninsured amount for each account based on the allocated uninsured amount of all plan participants with uninsured funds.

c) Based on the above determination, record the uninsured amounts to the accounts.

7) If there are uninsured funds for the employer in the business (“BUS”) right and capacity, then:


b) If there is an uninsured amount remaining after step 7(a), determine the employer’s BUS account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).



8) Based on the above determination, determine and record the uninsured amounts to the accounts in each ORC (EBP or BUS).


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9) The insured amount for each individual account is the difference between funds allocated to each ORC (EBP or BUS) and the uninsured amount.


4.2.8 Business Accounts


Determine if account meets FDIC requirements for a business account:

1) If the deposit account is owned by a corporation, partnership, or unincorporated association that is not engaged in independent activity,

17 then deposits are considered to be owned by the person(s) who

established the account or who own or control the corporation, partnership, or unincorporated association.

a) For these deposit accounts, determine the ORC based on the actual ownership of the account and calculate the deposit insurance based on either the Single Account or Joint Account right and capacity (Refer to Section 4.2.2 of this document for insurance determination for Single Accounts or Section 4.2.3 of this document for insurance determination for Joint Accounts).

2) If the account for an unincorporated association does not include the name of the unincorporated association in the account title, then the account is insured as the personal deposits of the officer(s) of the organization whose name(s) appear in the Account File, not as the funds of the organization as a business account.

a) For these deposit accounts, determine the ORC based on the actual ownership of the account and calculate the deposit insurance based on either the Single Account or Joint Account right and capacity (Refer to Section 4.2.2 of this document for insurance determination for Single Accounts or Section 4.2.3 of this document for insurance determination for Joint Accounts).

3) If the account is a sole proprietorship or doing business as (DBA) account, then the funds in the account are insured as a single account of the owner (Refer to Section 4.2.2 of this document for insurance determination for Single Accounts).

4) If the deposit account is owned by a corporation, partnership, or unincorporated association18

engaged in independent activity,

19 then set DP_Right_Capacity equal to BUS.

5) The corporation, partnership or unincorporated association of a business account is entitled to SMDIA for their combined amount of principal and accrued interest of all accounts under the BUS right and capacity at the same CI.

20

17

The term “independent activity” means that the entity is operated primarily for a legitimate business purpose and not solely to increase deposit insurance coverage. Separately incorporated subsidiaries engaged in an independent activity are separately insured from each other and from the parent company. 18

A corporation is defined as an organization that is incorporated under the laws of the state in which it is located. This definition includes both for-profit and not-for-profit corporations, as well as “Subchapter S,” “Limited Liability,” and professional corporations. A partnership is defined as an association of two or more persons or entities formed to carry on, as co-owners, an unincorporated business for profit. An unincorporated association is defined as an association of two or more persons formed for some religious, educational, charitable, social, or other non-commercial purpose. 19

Separately incorporated subsidiaries engaged in an independent activity are separately insured from each other and from the parent company. If a corporation has divisions that are not separately incorporated, deposits in the names of those divisions are not separately insured. Additionally, deposit accounts designated for different purposes but held by the same corporation are not separately insured. 20

Note if an entity has multiple signatories, officers, or partners, then the calculation of deposit insurance is unaffected as insurance calculations are made at the corporation, partnership, and unincorporated association level.


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4.2.8.2 Business Account Deposit Insurance Calculation

If all business accounts have been processed through Section 4.2.8.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 Pending File of this document):

1) Identify the corporation, partnership, or unincorporated association that owns the business account.

2) Aggregate total account balance and accrued interest of the corporation, partnership, or unincorporated association across all accounts the entity holds in the BUS ORC at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).



3) If there are uninsured funds for the corporation, partnership, or unincorporated association, then:


b) If there is an uninsured amount remaining after step a, allocate the remaining uninsured amount by following the liquidity priority order (see Section 4.2.16 of this document).



4) Based on the above determination, determine and record the uninsured amounts to each business account the corporation, partnership, or unincorporated association has at the CI.



4.2.9 Government Accounts


Determine if account meets FDIC requirements for a government account:

1) Identify number of official custodians with independent authority over funds for each account.

2) If an account is held by the Bureau of Indian Affairs on behalf of Native Americans at a CI, then see Section 4.2.14 of this document for Custodian Accounts for American Indians.

3) If an account is deposited by an insured depository institution pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy, then refer to Section 4.2.15 of this document for Accounts of an IDI Pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy.

4) If government account official custodians are unknown or if the CI cannot verify if custodians are official and/or can act with independent authority over funds in an account, then place account in the Pending File (see Section 5.4 of this document).

5) If an account is held by an official custodian of the United States, then SMDIA determination is equal to that of government accounts for public units located in the same state as the CI:

a) If the account is a time and savings account, not demand deposit account, then set DP_Right_Capacity equal to GOV1.


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b) If the account is a demand deposit account, not time and savings account, then set DP_Right_Capacity equal to GOV2.

6) If an account is held by an official custodian of a Native American tribe, then SMDIA determination is equal to that of government accounts for public units located in the same state as the CI:

a) If the account is a time and savings account, not demand deposit account, then set DP_Right_Capacity equal to GOV1.

b) If the account is a demand deposit account, not time and savings account, then set DP_Right_Capacity equal to GOV2.

7) If an account is not held by either an official custodian of a Native American tribe OR an official custodian of the United States:

a) If account is held by an official custodian in a CI located in the same state as the public unit and is a time and savings account,

21 not demand deposit account,

22 then set DP_Right_Capacity equal to GOV1.

b) If account is held by an official custodian in a CI located in the same state as the public unit and is a demand deposit account, not time and savings account, then set DP_Right_Capacity equal to GOV2.

c) If account is held by an official custodian in a CI located outside the state in which the public unit is located, then set DP_Right_Capacity equal to GOV3.

8) Each unique combination of official custodian, public unit, and government account DP_Right_Capacity (GOV1, GOV2, and GOV3) is entitled to SMDIA for the combined amount of all account interests at the same CI.

4.2.9.2 Government Account Deposit Insurance Calculation

If all government accounts have been processed through Section 4.2.9.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document):

1) Identify all unique combinations of official custodians, public units, and government account right and capacity DP_Right_Capacity (GOV1, GOV2, and GOV3).

2) Aggregate total account balance and accrued interest by each unique combination of official custodians, public units, and government account right and capacity DP_Right_Capacity (GOV1, GOV2, and GOV3). If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) For each of the aggregated amounts above:

21

The following deposit types are included within the definition of “Time and Savings”

NOW Account (these are deposits on which the depository institution has reserved the right to require at least 7 days written notice prior to withdrawal or transfer of any funds from the account)

Savings

Certificate of Deposit (CD)

Money Market Deposit Account (MMDA) 22

For coverage under the Government Accounts category, accounts are grouped into two categories: Demand Deposit Accounts and Time and Savings Accounts. A Demand Deposit Account is a deposit that is payable on demand and for which the depository institution does not reserve the right to require at least seven days' written notice of an intended withdrawal. The following deposit types are included within the definition of Demand Deposit Accounts:

Checking (Non-Interest and Interest bearing)


Page | 34

a) If the total balance and accrued interest does not exceed SMDIA times the number of official custodians, then the funds are fully insured.

b) If the total balance and accrued interest does exceed SMDIA times the number of official custodians, then funds in excess of SMDIA are not insured.

4) If there are uninsured funds, then:

a) If the government entity has an outstanding security pledge with the CI, then place the account in the Pending File (see Section 5.4 of this document).

b) If the government entity does not have an outstanding security pledge with the CI, then:

i) Apply the uninsured amount to the accrued interest of all such accounts (if any).

ii) If there is an uninsured amount remaining after step 4(b)(i), determine the government account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

iii) If after step 4(b)(ii), there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance and accrued interest first.

iv) If after step 4(b)(iii), there are multiple accounts with the same product type that exceed SMDIA with the same total balance and accrued interest, the CI should select an account for which to apply the uninsured amount.

5) Based on the above determination, record the uninsured amounts to the accounts.



4.2.10 Mortgage Servicing Accounts


Determine if account meets FDIC requirements for a mortgage servicing account:

1) If the deposit account opened by a mortgage servicer is for deposits representing the commingled payments of taxes and insurance (“T&I”) premiums, then confirm account meets the titling and recordkeeping requirements for fiduciary accounts (see Section 4.1.4 of this document).

2) If the deposit account is a deposit account opened by a mortgage servicer for the purpose of holding commingled payments of principal and interest (“P&I”) made by mortgagors, then set DP_Right_Capacity equal to MSA.

3) If there is overfunding of a mortgage servicing account, then set DP_Right_Capacity equal to BUS for the overfunding and set the account owner to the mortgage servicer.

4) Identify each unique mortgagor and the total account balance and accrued interest each mortgagor has in the mortgage servicing account based on the account information for the insurance calculation.

5) If the identity of mortgagors or their share is not available, then place account in the Pending File (see Section 5.4 of this document).

6) Each unique combination of mortgagor and mortgage servicer’s P&I payment in all mortgage servicing accounts at the same CI is entitled to SMDIA.

7) The mortgage servicer of mortgage servicing accounts for the combined amount of its overfunding in all mortgage servicing accounts at the same CI is entitled to SMDIA.

4.2.10.2 Mortgage Servicing Account Deposit Insurance Calculation


Page | 35

If all mortgage servicing accounts have been processed through Section 4.2.10.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then for all unprocessed accounts:

1) Identify all unique combinations of mortgage servicer and mortgagor.

2) Aggregate total account balance and accrued interest associated with P&I payments by each unique combination of mortgage servicer and mortgagor for those accounts held in the MSA ORC. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) Aggregate total account balance and accrued interest by each mortgage servicer for all overfunding (if any) and insure the total funds of each mortgage servicer under the Business Account right and capacity (together with the other funds each mortgage servicer has under the Business Account ORC at the same CI). If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

4) Aggregate the total T&I payments contributed by each mortgagor (if any) across the mortgage servicers and aggregate the total T&I funds of each mortgagor with the other funds each mortgagor has under the same ORC at the same CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).




6) After going through Steps 5(a) and 5(b), determine the uninsured amounts for the unique combination of mortgagor and mortgage servicer under the MSA right and capacity, by mortgage servicer under the BUS right and capacity (if applicable), and by mortgagor under the respective ORC (if applicable).

7) For each mortgage servicer (or mortgagor), if there are uninsured funds under an ORC other than MSA, then perform the following steps for all accounts associated with the mortgage servicer (or the mortgagor) under each of such right and capacity:

a) Apply the uninsured amount first to the accrued interests (if any) of all accounts.

b) If there is an uninsured amount remaining after step 7(a), determine the accounts that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).


d) If after step7(c), there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

e) Based on the above determination, determine the uninsured amount to each mortgage servicing account under the corresponding ORC.

8) Determine the uninsured amount for each mortgage servicing account based on results from step 7 and record the uninsured amount for that mortgage servicing account by ORC.




Page | 36

4.2.11 Accounts held by a Depository Institution as the Trustee of an Irrevocable Trust


Determine if account meets FDIC requirements for an account held by a depository institution as the trustee of an irrevocable trust:

1) Identify the trust fund owner or beneficiary.23

2) If the account meets the definition of an account held by a depository institution as the trustee of an irrevocable trust (see Appendix B), then set DP_Right_Capacity equal to DIT.

3) Each trust account owner or beneficiary represented is entitled to SMDIA for the combined amount of his or her interests in all accounts under the DIT ORC at the CI.

4.2.11.2 Deposit Insurance Calculation for Accounts Held by a Depository Institution as the Trustee of an Irrevocable Trust

If all accounts held by a depository institution as the trustee of an irrevocable trust have been processed through Section 4.2.11.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 Pending File), then:

1) Identify all trust fund owner(s) or beneficiaries.

2) Aggregate the total account balance and accrued interest of each trust fund owner or beneficiary for all accounts the trust owner or beneficiary holds with the same depository institution and for the same trust under the DIT ORC at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) For the aggregated account balance and accrued interest of each trust fund owner or beneficiary:



4) If there are uninsured funds for the trust fund owner or beneficiary, then:


b) If there is an uninsured amount remaining after step a, determine the DIT account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

c) If after step 4(b) there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.

d) If after step 4(c) there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

5) Based on the above determination, determine and record the respective uninsured amount of each DIT account the trust fund owner or beneficiary has at the CI.

6) Determine the insured amount for each DIT account and trust account owner or beneficiary as the difference between his or her funds in the account and the uninsured amount.

7) Flag the accounts that have been processed as an insurance determination is completed.

23

The trust fund owner is the owner of the trust funds held by the depository institution as a trustee for an irrevocable trust. The trust fund owner can be the grantor (for the retained interest) or the beneficiary named in the irrevocable trust document.


Page | 37

4.2.12 Annuity Contract Accounts


Determine if account meets FDIC requirements for an annuity contract account:

1) Confirm the titling of the annuity contract deposit reflects the relationship between the annuitant and the insurance company.

2) Check the following to insure the account meets the definition of the annuity contract account for purpose of deposit insurance:

a) The account cannot be charged with the liabilities arising out of any other business of the insurance company or corporation.

b) The account cannot be invaded by the insurance company or the corporation’s other creditors if the corporation becomes insolvent and its assets are liquidated.

c) In case either of the above two requirements is not met, determine the ORC of the funds in the account based on actual ownership of the funds.

3) If the account meets the definition of the annuity contract account (see Appendix B), then set DP_Right_Capacity equal to ANC.

4) If there is overfunding in an annuity contract account contributed by the insurance company or the corporation that does not belong to any of the annuitants, then treat the overfunding amount as funds under the BUS ORC and insure it together with the funds the insurance company or corporation has in all other accounts under the BUS ORC at the CI (Refer to Section 4.2.8 of this document for insurance determination for the Business Accounts).

5) For all ANC accounts associated with the insurance company/corporation and the annuitant, determine whether applicable state law provides that the funds held in these ANC accounts are owned by the insurance company/corporation, or alternatively, by the annuitant:

a) For accounts in which funds are owned by the insurance company/corporation, determine all unique combinations of insurance company/corporation and annuitant and the total account balance and accrued interest attributed to each such combination.

i) Funds attributable to each unique combination are insured up to the SMDIA.

b) For accounts in which funds are owned by the annuitant, determine the total account balance and accrued interest attributable to each annuitant (potentially across multiple accounts held by different insurance companies at the CI).

i) Funds attributable to each annuitant are insured up to the SMDIA.

6) The overfunding amount, together with the funds the insurance company or corporation has in all other accounts under the BUS right and capacity at the CI, are entitled to SMDIA. Refer to Section 4.2.8 of this document for insurance determination for Business Accounts.

4.2.12.2 Annuity Contract Accounts Deposit Insurance Calculation

If all annuity contract accounts have been processed through Section 4.2.12.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 Pending File), then:

1) Identify either each unique annuitant or each unique combination of insurance company/corporation and annuitant, as determined under step 5 of Section 4.2.12.1 of this document.

2) Aggregate total account balance and accrued interest for either each unique annuitant or each unique combination of insurance company/corporation and annuitant for all accounts held in the ANC ORC at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified


Page | 38

account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) Aggregate total account balance and accrued interest by insurance company or corporation for all overfunding (if any) and insure it together with the funds each insurance company or corporation has in all other business accounts at the CI under the BUS right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

4) For each of the aforementioned aggregations (under ANC or BUS right and capacity):



c) After processing steps 4a and 4b, determine the uninsured amounts for either each unique annuitant or each unique combination of insurance company/corporation and annuitant under the ANC right and capacity and by insurance company/corporation under the BUS right and capacity (if applicable).

5) For either each unique annuitant or each unique combination of insurance company/corporation and annuitant, if there are uninsured funds under the ANC right and capacity, then perform the following steps for all ANC accounts the annuitant has with the insurance company at the CI:


b) If there is an uninsured amount remaining after step 5(a), determine the accounts that will be uninsured by following the liquidity priority order (see Section 4.2.16 of this document).



e) Based on the above determination, determine the uninsured amount to each ANC account the annuitant has or the annuitant has with the insurance company under the ANC ORC.

6) For each insurance company or corporation, if there are uninsured funds under the BUS right and capacity, then perform the following steps for all business accounts the insurance company or corporation has at the CI:


b) If there is an uninsured amount remaining after step 6(a), determine the accounts that will be uninsured by following the liquidity priority order (see Section 4.2.16 of this document).



e) Based on the above determination, determine the uninsured amount to each account the insurance company or corporation has under the BUS right and capacity.

7) Determine the uninsured amount for each annuity contract account based on results from step 5 and step 6 and record the uninsured amount for that annuity contract account by ORC (ANC and BUS).

8) The insured amount for accounts of each annuitant or each combination of annuitant and insurance company/corporation (in the ANC ORC) or accounts of each insurance company/corporation (in the BUS right and capacity) is the difference between the funds in each ORC and the corresponding uninsured amount.

9) Flag accounts that have been processed as insurance determination is completed.


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4.2.13 Public Bond Accounts


Determine if account meets FDIC requirements for a public bond account:

1) Identify all unique combinations of bond issuers and bondholders.

2) If account meets the definition of a public bond account (see Appendix B), then set DP_Right_Capacity equal to PBA.

3) Identify each of the unique bondholders and the total account balance and accrued interest each bondholder has in the public bond account based on their respective beneficial interest for the insurance calculation

4) If the identification of bondholders and their beneficial interests is not complete, then place the account in the Pending File (see Section 5.4 of this document).

5) Each unique combination of bondholder’s beneficial interest in a public bond account and bond issuer at the same CI is entitled to SMDIA.

4.2.13.2 Public Bond Account Deposit Insurance Calculation

If all public bond accounts have been processed through Section 4.2.13.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 of this document), then:

1) Identify all public bond accounts by unique combination of bondholder and bond issuer of the public bond account.

2) Aggregate the total balance and accrued interest by each unique combination of bondholder and bond issuer under the PBA ORC. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) For the aforementioned aggregation:


b) If the total balance and accrued interest do exceed SMDIA, then funds in excess of SMDIA are not insured.

4) After going through steps 3(a) and 3(b), determine the uninsured amounts for the unique combination of bondholder and bond issuer under the PBA ORC.

5) For each combination of public bond issuer and bondholder, if there are uninsured funds under the PBA ORC, then:

a) Apply the uninsured amount first to the accrued interests (if any) of all such accounts.

b) If there is an uninsured amount remaining after step 5(a), determine the account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).


d) If after step 5(c), there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account (or accounts) for which to apply the uninsured amount.

e) Based on the above determination, determine the uninsured amount to each public bond account held by the bondholder with the bond issuer under the PBA ORC.

6) Determine the total uninsured amount for each public bond account of each bond issuer based on results from step 5 and record the uninsured amount for that public bond account in the PBA ORC.


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7) The insured amount for each individual account is the difference between the funds in the PBA ORC and the corresponding uninsured amount.


4.2.14 Custodian Accounts for American Indians

24


Determine if account meets FDIC requirements for a custodian account for American Indians:

1) Identify the Native American(s) for which the deposit account is held by the Bureau of Indian Affairs (“BIA”).

2) Check the following to confirm the account meets the definition of the custodian account for Native Americans for purpose of deposit insurance:

a) The account records indicate the funds are held by the disbursing agent in an agency capacity.

b) The disbursing agent must hold the funds pursuant to 25 U.S.C. 162 (a) or similar authority.

c) The Native American must have an ascertainable interest in the funds.

d) In case either of the above three requirements is not met, determine the ORC of the funds in the account based on actual ownership of the funds.

3) If the account represents the personal deposit of a Native American or Native Americans and the funds are not held by the BIA, then refer to Sections 4.2.2 for insurance determination for the Single Accounts or Section 4.2.3 for the Joint Accounts.

4) If the account represents accounts held by an official custodian of a Native American tribe and the funds are not held by the BIA, then refer to Section 4.2.9 for insurance determination for the Government Accounts.

5) If account meets the definition of a custodian account for Native Americans (Appendix B), then set DP_Right_Capacity equal to BIA.

6) Custodian accounts for American Indians are insured up to SMDIA for each Native American for whom the BIA is acting.

4.2.14.2 Deposit Insurance Calculation

If all Custodian Accounts for American Indians have been processed through Section 4.2.14.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 Pending File), then:

1) Identify all Native Americans for which deposits of the account are held.

2) Determine the amount each Native American is entitled to in the account.

3) Aggregate the deposits across all BIA accounts each Native American holds at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

4) For the aggregated amount each Native American holds in the BIA ORC at the CI:

a) If the amount does not exceed SMDIA, then the funds are fully insured.

b) If the amount exceeds SMDIA, then funds in excess of SMDIA are not insured.

5) If there are uninsured funds for a Native American, then:


24

FDIC regulations use the term “American Indian” when referencing accounts of Native Americans.


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b) If there is an uninsured amount remaining after step 5(a), determine the account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).


d) If after step 5(c), there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account (or accounts) for which to apply the uninsured amount.

6) Based on the above determination, determine the uninsured amount for each BIA account.

7) Determine the insured amount for each Native American as the difference between his or her interest in the account and the uninsured amount.


4.2.15 Accounts of an IDI Pursuant to the Bank Deposit Financial Assistance Program of the Department of

Energy


Determine if account meets FDIC requirements for an account of an IDI pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy:

1) Identify the IDI holding the account pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy.

2) If the account represents the deposits of an IDI not pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy, then see Section 4.2.8 for insurance determination for the Business Accounts.

3) If account meets the definition of an account of an IDI pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy at the CI (see Appendix B), then set DP_Right_Capacity equal to DOE.

4) Each IDI is entitled to SMDIA for the combined amount of their deposits in all accounts under the DOE ORC at the same CI.

4.2.15.2 Deposit Insurance Calculation

If all accounts pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy have been processed through Section 4.2.15.1 Right and Capacity and SMDIA Determination or placed in the Pending File (see Section 5.4 Pending File), then:

1) Identify the IDI and all accounts the IDI has under the DOE ORC at the CI.

2) Aggregate total account balance and accrued interest of each IDI for those accounts held in the DOE ORC. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

3) For the aggregated account balance and accrued interest for each IDI:



4) If there are uninsured funds for the IDI, then:


b) If there is an uninsured amount remaining after step 4(a), determine the DOE account(s) of the IDI that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).


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c) If post after 4(b), there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.


5) Based on the above determination, determine the uninsured amount of each DOE account the IDI has at the CI.

6) Determine the insured amount for each DOE account the IDI has at the CI as the difference between the sum of current balance and accrued interest and the uninsured amount.


4.2.16 Liquidity Priority Order

After the deposit insurance determination is completed, uninsured funds are to be debited from accounts in the following order:

1. Certificate of deposit

2. Savings account

3. Money market account

4. Negotiable order of withdrawal

5. Demand deposit account

6. Outstanding official item

If a depositor has only one account that is uninsured, the calculation of debit amount is simply subtracting the insured amount from total balance (principal plus accrued interest). The debit will be applied to the accrued interest first, then the principal. If a depositor has more than one account in a deposit insurance category, the calculation of debit amounts is determined by debiting accrued interests across all accounts first then by the liquidity priority order listed above and then by the highest principal amount if there are multiple accounts with the same liquidity order.

4.3 Apply Funds

Once all the accounts have been processed through sections 4.1 and 4.2 of this document, apply the uninsured and insured balances to the appropriate accounts and proceed to section 5 of this document for Output File Generation Requirements.


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5 Output File Generation Requirements

The following section provides an overview of the steps each CI should follow when populating the four Output Files described in Appendix A (Customer File, Account File, Account Participant File, and Pending File). Appendix A defines the fields that each CI must provide. It is expected that each CI will provide all information described in Appendix A unless noted otherwise.

All Output Files contain the CS_Unique_ID field which should be unique to each CI depositor and provide a common key linking all files. The Account Participant File is linked to the Account File by the CS_Unique_ID, the DP_Right_Capacity and the DP_Acct_Identifier. The file relationships should conform to the following rules:

— Each account represented on the Account File or the Account Participant File should have a corresponding customer record in the Customer File.

— Each account represented on the Account Participant File should have a corresponding account on the Account File.

— Each Account on the Pending File should not appear on the Account File, except in the case of pass-through accounts.

— Each Account Participant that is also a Customer of the CI should have the same AP_Participant_ID as its CS_Unique_ID at the CI.

In the case of a CI that has acquired or merged with another IDI, the “Six-Month Rule” (12 CFR § 330.4) may apply. In this case, the newly acquired deposits are separately insured from any accounts a depositor may already have at the acquiring CI for an initial period of six months. Additional scenarios may result in changes in insurance coverage. A CI should carefully review deposit accounts to determine whether they are eligible for the “Six-Month Rule.” A CI with accounts subject to the Six-Month Rule should separately populate the four Output Files for each IDI it has acquired.

5.1 Output File Population – Customer File

The Customer File should be populated with the information described in Appendix A except as noted below:

1) In the case of accounts where an account is held by an entity, the CS_Entity_Name should be populated and the customer information fields should be populated with the contact information of a person associated with the account.

2) In the case of an account with multiple owners, there should be one customer with a CS_Unique_ID for each account owner. For example, a JNT account owned by Harry and Joan Smith would result in the creation of two customer records and two CS_Unique_IDs on the Customer File.

3) In the case of Pass-Through Accounts, the Customer File should be populated for each of the account’s beneficial owners as information about the beneficial owner is obtained. Each beneficial owner must receive its own CS_Unique_ID. In cases where a beneficial owner is already a customer of the CI, the CI should match the customer to its existing CS_Unique_ID.

4) The CS_Security_Pledge_Flag only applies to government accounts and should not be populated for other customer types. The CI should undertake every effort to confirm that Official Custodians are in fact Official Custodians of a GOV account and not simply authorized signatories to the account before including them in the Customer File, as required by 12 C.F.R. §330.15(b).


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5.2 Output File Population – Account File

The table below defines the considerations for the creation of the Account File and provides information for only those data fields where the population of the field varies by ORC. A complete list of the attributes for each file is contained in Appendix A.

1) A separate row should be populated for each owner of an account in the JNT, EBP, DIT, ANC, REV, GOV, and IRR ORCs. For example, a JNT account held by Harry and Joan Smith would result in two rows being populated in the Account File (one for Harry and one for Joan).

2) In the case of Pass-Through Accounts (e.g. brokered deposits), a CI should populate one row in the Account File for each beneficial owner and an additional record for the fiduciary’s account at the CI. Please reference the example provided in Section C.15 in Appendix C. The DP_Prepaid_Account_Flag, DP_PT_Account_Flag and the DP_PT_Trans_Flag should be populated in accordance with the definitions in Part 370 and should be consistent with the product type indicated in the DP_Prod_Cat field on the Account File.

Field Data Field Population Instructions

CS_Unique_ID One CS_Unique_ID is populated for each account owner. In the case of JNT, EBP, DIT, ANC, REV, GOV, and IRR accounts, there may be multiple rows populated with a CS_Unique_ID for each DP_Acct_Identifier.

DP_Acct_Identifier One DP_Acct_Identifier is populated for each account. In the case of JNT, EBP, DIT, ANC, REV, GOV, and IRR accounts, there may be multiple rows populated with the same DP_Acct_Identifier.

DP_Allocated_Amt DP_Allocated_Amt is populated with the Current Account Balance for the Account associated with the Account Identifier. In the case of JNT, EBP, DIT, ANC, REV, GOV, and IRR accounts, the DP_Allocated_Amt is populated with the current account balance allocated to the owner identified in the CS_Unique_ID Field for the row

DP_Acc_Int DP_Acc_Int is populated with interest that is earned but not yet paid for the account specified in the DP_Acct_Identifier. In the case of JNT, EBP, DIT, ANC, REV, GOV, and IRR accounts, the DP_Acc_Int is populated with the interest that is earned but not yet paid that is allocated to the owner identified in the CS_Unique_ID Field for the row, as specified in Section 4.2 of this document

DP_Hold_Amount DP_Hold_Amount is populated with the account balance subject to a hold for the account specified in the DP_Acct_Identifier. In the case of JNT, EBP, DIT, ANC, REV, GOV and IRR accounts, the DP_Hold_Amount is populated with amount subject to a hold that is allocated to the owner identified in the CS_Unique_ID Field for the row. All holds applicable to the account should be aggregated before they are allocated between rows.

DP_Insured_Amount Populate DP_Insured_Amount by following the procedures for the ORC, as specified in Section 4 of this document.

DP_Uninsured_Amount Populate DP_Uninsured_Amount by following the procedures for the ORC, as specified in Section 4 of this document.

5.3 Output File Population – Account Participant File

The table below defines the considerations for the creation of the Account Participant File and provides information for only those data fields where the population of the field varies by ORC. A complete list of the attributes for each file is contained in Appendix A. An Account Participant File would not be created for accounts in the SGL, JNT, CRA, BUS, BIA, and DOE ORCs. The following instructions apply to accounts in the REV, IRR, EBP, ANC, DIT, GOV, MSA, and PBA ORCs. As in the Account File, a separate row should be populated for each owner of an account in the JNT, EBP, DIT, ANC, REV, GOV, and IRR ORCs. In addition, the Account Participant File should be joined to the Account File by


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CS_Unique_ID, DP_Acct_Identifier, and DP_Right_Capacity. For example, a REV account held by Harry and Joan Smith with John Smith as a beneficiary would result in two rows being populated in the Account Participant File (One row for John Smith as Harry’s beneficiary and one for John Smith as Joan’s beneficiary).


CS_Unique_ID One CS_Unique_ID is populated for each account owner. In the case of JNT, EBP, DIT, ANC, REV, GOV, and IRR accounts, there may be multiple rows populated with a CS_Unique_ID for each DP_Acct_Identifier.


AP_Allocated_Amount Populate AP_Allocated_Amt with the Current Account Balance Allocated to the Account Participant specified in the AP_Participant_ID Field for the Account Specified in the DP_Acct_Identifier Field.

AP_Participant_ID One AP_Participant_ID is populated for each account participant of the account specified in the DP_Acct_Identifier Field. The AP_Participant_ID can be repeated if the account has multiple owners or if the Account Participant is a participant/beneficiary of multiple accounts. Each account participant that is also a Customer of the CI should have the same AP_Participant_ID as its CS_Unique_ID at the CI. If an account participant is not an existing customer of the CI, the AP_Participant_ID should be applied in accordance with the rules for the CS_Unique_ID defined in the Customer File section of Appendix A.

5.4 Output File Population – Pending File

The table below defines the considerations for the creation of the Pending File and provides information for only those data fields where the population of the field varies by ORC. A complete list of the attributes for each file is contained in Appendix A. A Pending File could be populated with any ORC.

1) In the case of Pass-Through Accounts (e.g. brokered deposits), a CI should populate one row in the Pending File for each beneficial owner of the applicable account types. Please reference the example provided in Appendix C Section 17 – Use Cases for an example broker/sweep account scenario.


CS_Unique_ID One CS_Unique_ID is populated for each account owner. In the case of JNT, EBP, DIT, ANC REV, GOV, and IRR accounts, there may be multiple rows populated with a CS_Unique_ID for each DP_Acct_Identifier.


DP_Right_Capacity Pass-through Accounts, such as sweep accounts or brokered deposits, should populate the DP_Right_Capacity with a Null value until the underlying account owner information has been gathered and processed.

DP_Acc_Int DP_Acc_Int is populated with interest that is earned but not yet paid for the account specified in the DP_Acct_Identifier. In the case of JNT, EBP, DIT, ANC, REV, GOV, and IRR accounts, the DP_Acc_Int is populated with the interest that is earned but not yet paid that is allocated to the owner identified in the CS_Unique_ID Field for the row.

CS_Security_Pledge_Flag The CS_Security_Pledge_Flag is only populated for GOV accounts and is populated when the government entity has an outstanding security pledge with the CI.


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6 Control Report Requirements

The following provides an overview of the control report requirements that will assist the CI to ensure accuracy and completeness of the submission to the FDIC. Additionally these control report requirements and outputs will be leveraged by the FDIC in conducting auditing and testing of the CI.

6.1 Data Movement

Data movement describes the process by which data is transferred from various source systems at the CI to its target state in regulatory reports. An effective data movement process will give both the CI and the FDIC confidence that data is fit for all intended purposes at all stages in the process, that its accuracy and completeness is maintained when moved or transformed, and that the data can be traced from source to target and from target to source.

6.1.1 Data Movement Policies and Standards

A CI must ensure that all data movements that are created or modified as a part of complying with Part 370 utilize existing enterprise standards and policies.

1. A CI must be able to demonstrate the application of the standards and policies for the deposit insurance calculation and any exceptions granted with supporting evidence.

6.1.2 Data Movement Accountability and Issue Ownership

Accountability is the foundation of an effective data movement process. Accountable parties must be identified and their roles and responsibilities must be clearly and unambiguously communicated.

1. A CI must be able to demonstrate who the accountable parties are at each data movement and how existing data governance structures are used for identifying, resolving, and reporting data movement issues that may arise.

2. A CI should be able to demonstrate senior management engagement in defining roles and responsibilities.

6.1.3 Completeness of Data Movement

A key risk in any data movement process is the failure to transfer all records from one system to the next, which may result in the incorrect calculation of deposit insurance or a loss of data lineage. This loss of completeness could occur with account level information, financial data, and nonfinancial data. To mitigate this risk, it is critical that the CI adheres to the following requirements:

1. A CI must demonstrate that it can trace data from source to target and from target to source. 2. A CI must be able to demonstrate the reconciliations of financial and nonfinancial data at each data

movement in a manner consistent with its enterprise data management policies and standards. 3. A CI must document data flow between systems in a manner consistent with its enterprise data

management program, including business and technical lineage and calculations.

6.1.4 Accuracy of Data Movement

A key risk in a data movement process is that the failure to accurately transfer critical data from one system to the next resulting in the incorrect calculation of deposit insurance or a loss of data lineage. This loss of accuracy could occur with account level information, financial data, nonfinancial data, or other critical data elements (“CDEs”). To mitigate this risk, it is critical that the CI adheres to the following requirements:

1. A CI must demonstrate that CDEs were transferred accurately between systems, such as social security numbers not being truncated.

2. A CI must document and govern all data flows and transformations that occur as data is moved from one system to the next, consistent with data completeness and lineage requirements.


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3. A CI must establish roles and responsibilities and identify contacts responsible for the accuracy of each data movement.

6.1.5 Data Transformation and Calculations

Data transformations and calculations often occur as data moves through a deposit insurance calculation system. A risk in any data transformation or calculation is that a failure to properly manipulate critical data results in inaccurate data, loss of data lineage, and/or an incorrect deposit insurance calculation. For example, incorrect or inaccurate business rules could result in an incorrect calculation of deposit insurance and incomplete business rules could result in a failure to perform deposit insurance calculations. As a result, it is critical that the CI adheres to the following requirements:

1. A CI must ensure that data transformation and calculation processes are identified and documented (e.g., establishing a metadata repository).

2. A CI must ensure that data transformation and calculation processes are aligned with broader enterprise-wide policies and standards (e.g., standard identifiers and classification schemes are consistent across the enterprise).

6.1.6 Manual Data Entry and File Imports

Manual data entries and file imports introduce increased data movement and manual intervention risks. Failure to accurately input, review, and approve manual adjustments or file imports can result in inaccurate data, loss of data lineage, and/or an incorrect deposit insurance calculation. As a result, it is critical that the CI institutes controls around manual data entry and file imports that are consistent with enterprise data management standards and that ensure proper separation of duties between data input, review, and approval.

6.2 Data Quality

Data quality describes the degree to which data is fit for its intended use. The overall goal of data quality as it relates to Part 370 is to ensure that the data used to calculate deposit insurance is fit for its intended purpose and any issues are known prior to any required deposit insurance calculation.

6.2.1 Data Quality Policies and Standards

A CI’s data quality policy must be applied to the timely deposit insurance calculation process to ensure that data quality is governed and consistently evaluated for the “what/how/who” of data quality. As a result, it is critical that the CI adheres to the following requirements:

1. A CI must design, develop, and document a data quality policy or must apply existing data quality policy to the timely deposit insurance calculation process.

2. A CI must communicate the data quality policy to relevant stakeholders, incorporate feedback from stakeholders and be approved by the appropriate level of management.

6.2.2 Data Quality Accountability

Accountability is the foundation of effective data movement or transfer processes. Accountable parties must be identified and their roles and responsibilities must be clearly and unambiguously communicated. As a result, it is critical that the CI adheres to the following requirements:

1. A CI must be able to demonstrate the accountable parties for data quality deposit insurance calculation data and the existing data governance structures for identifying, resolving, and reporting data quality issues.

2. A CI should be able to demonstrate senior management engagement in defining of roles and responsibilities for data quality accountability and oversight.


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6.2.3 Data Quality Assessment and Remediation

When performing a data quality analysis of existing data, it is critical that the CI include all relevant data in order to determine the true state of data quality as it relates to the data used to calculate deposit insurance. Additionally, the CI should embed ongoing mentoring and remediation strategies consistent with existing data quality and governance initiatives. As a result, it is critical that the CI adheres to the following requirements:

1. A CI must have a set of CDEs defined for the information it uses to calculate deposit insurance. 2. A CI must be able to profile, analyze, and grade the existing data which contribute to the deposit

insurance. 3. A CI must be able to demonstrate how it tracks the quality of the data over a period of time and how

responsible parties are engaged to review data quality performance. 4. A CI must be able to demonstrate its data remediation plans, specifically it should be able to demonstrate

how issues are analyzed and prioritized based on the importance of the issue and impact to the deposit insurance calculation.

5. A CI must be able to demonstrate how systemic data quality issues are addressed by the implementation of controls in source/origination systems consistent with remediation plans.

6.3 Control Reports

The overall goal of control reporting is to monitor risk in the CI’s systems and to support a certification of compliance. An efficient control report process will give both the CI and the FDIC confidence that data being produced is accurate and complete and that data can be traced from source to target and from target to source. Control reports may help monitor data movement and data quality issues throughout the deposit insurance calculation process. Additionally, control reports may help to review effectiveness of controls built around reconciliation points. As a result, the CI must be capable of evidencing a three-way reconciliation between general ledger, deposit systems, and Output Files by producing the following control reports:

1. Control Report 1 – General Ledger to Deposit Systems: a. Reconcile the total balance of insurable accounts in the deposit systems of the CI to the total

balance of insurable accounts as maintained in the general ledger of the CI. b. Reconcile the total balance of uninsurable accounts in the deposit systems of the CI to the total

balance of uninsurable accounts as maintained in the general ledger of the CI. c. Reconcile the total balance of insurable and uninsurable accounts in the deposit system of the CI

to the total balance of insurable and uninsurable accounts as maintained in the general ledger of the CI.

2. Control Report 2 – Output Files to the General Ledger/Deposit Systems:

a. Reconcile the sum of DP_Total_PI to the sum of insured and uninsured balances in the general ledger/deposit systems.

b. Reconcile sum of DP_Total_PI on the Account File and DP_Total_PI on the Pending File to the total balance in the general ledger/deposit systems for insurable accounts.

i. Brokered deposits that are represented on the Account File with a null ORC need to be excluded from total balance.


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7 Summary Report Requirements

The overall goal of summary reporting requirements is to produce a snapshot of information at any point in time that will provide the FDIC and CI with insight into the deposit insurance calculation process and to assist in managing workload and throughput at the time of failure. The CI’s system must have the requisite technical architecture and management reporting systems to be able to produce the following summary reports in line with Part 370:

1. Account Summary Reports showing deposit amount and number of deposit accounts by ORC. Additional details that the CI’s system should be able to provide include: — Insured and uninsured balances of accounts by ORC where a calculation has been completed — Indicative information regarding deposit account balances including, mean, median, and quartile

ranking Similar to the Account Summary Reports listed above, the CI’s system should be able to generate the following types of summary reports:

1. Pending File Report that provides the total number of deposit accounts and the dollar amount of deposits by ORC that are pending insurance calculation.

2. Fiduciary Report that identifies brokers/fiduciaries by account backlog and unknown insurance exposure. 3. Approval Report that identifies the total number of deposit accounts and the dollar amount of deposits

by ORC that are approved by FDIC claims agents or are pending approval.


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8 Certification of Compliance

The following link provides a sample certification of compliance in accordance with Part 370, section 10(a). The certification is made by the CEO or COO and indicates that the CI has successfully tested systems for compliance with Part 370. The letter is for sample purposes only and may be modified to conform to the specific circumstances of the CI.

[TO BE PROVIDED].


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Appendix A Explanation of Output File Generation Capabilities

The Output Files will include the data necessary for the FDIC to determine the deposit insurance coverage in a resolution. A CI’s system must have the capability to prepare and maintain the files detailed below. These files must be prepared in successive iterations as the FDIC receives additional data from external sources necessary to complete the deposit insurance determinations, and, as it updates pending determinations. The files will be comprised of the following four tables. The unique identifier is required in all four tables to link the depositor information.

Customer File

The Customer File will be used by the FDIC to identify the customers. One record represents one unique customer. The data elements will include:

# Field Name Description Format

1 CS_Unique_ID This field is the unique identifier that is the primary key for the Depositor Data record. It will be generated by the CI and there can be no duplicates.

Variable Character.

2 CS_Govt_ID This field should contain the ID number that identifies the entity based on a government issued ID or corporate filing. It is assumed that the following will be populated: — For a US Individual - Legal identification number

(e.g. SSN, TIN, Driver's License or Passport Number)

— For a Foreign National Individual - where a SSN or TIN doesn't exist a foreign passport or other legal identification number (e.g. Alien Card)

— For a Non-individual - the Tax identification Number (TIN), or other registered entity number

Variable Character.

3 CS_Govt_ID_Type The valid customer identification types, are noted below: — SSN = Social Security Number — TIN = Tax Identification Number — DL = Driver's License, issued by State or

Territory of the U.S. — ML = Military ID — PPT = Valid Passport — AID = Alien Identification Card — OTH = Other

Character (3).


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4 CS_Type The customer type field indicates the type of entity the customer is at the CI. The valid values are: — IND = Individual — BUS = Business — TRT = Trust — NFP = Non-Profit — GOV = Government — OTH = Other

Character (3).

5 CS_First_Name Customer first name. Use only for name of individuals, and the primary contact for an entity.

Variable Character.

6 CS_Middle_Name Customer middle name. Use only for name of individuals, and the primary contact for an entity.

Variable Character.

7 CS_Last_Name Customer last name. Use only for name of individuals, and the primary contact for an entity.

Variable Character.

8 CS_Name_Suffix Customer suffix such as ‘‘Jr’’ Variable Character.

9 CS_Entity_Name The registered name of the entity; this field should not be used for individual .

Variable Character.

10 CS_Street_Add_Ln1 Street address line 1. The current account statement mailing address of record.

Variable Character.

11 CS_Street_Add_Ln2 Street address line 2. If available, the second address line.

Variable Character.

12 CS_Street_Add_Ln3 Street address line 3. If available, the third address line.

Variable Character.

13 CS_City The city associated with the permanent legal address.

Variable Character.

14 CS_State The state for US addresses or state/province/county for international addresses. — For US Addresses use a two-character state

code (official U.S. Postal Service abbreviations) associated with the permanent legal address.

— For international address follow that country state code. Example is two letter abbreviation for provinces in Canada would be used.

Variable Character.

15 CS_ZIP The Zip/Postal Code associated with the customer's permanent legal address. — For US zip codes, use the U.S. Postal Service

ZIP+4 standard — For international zip codes follow that standard

format of that country. Example is UK zip code format that would include letters and numbers.

Variable Character.

16 CS_Country The country associated with the permanent legal address. Provide the country name or the standard International Organization for Standardization country code.

Variable Character.

17 CS_Telephone Customer telephone number. The telephone number on record for the customer, including the country code if not within the United States

Variable Character.


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18 CS_Email The email address on record for the customer Variable Character.

19 CS_Outstanding_Debt_Flag This field indicates if the customer has outstanding debt with CI, it may be used to help determine offset. Enter "Y" if customer has outstanding liabilities with CI, enter "N" otherwise.

Character (1).

20 CS_Security_Pledge_Flag This field indicates if the CI has pledged securities to the government entity, to cover any shortfall in deposit insurance. Enter "Y" if the government entity has outstanding security pledge with CI, enter "N" otherwise. This field should only be used for government customers.

Character (1).

Account File

The Account File contains the deposit ownership rights and capacities information, allocated balances, insured amounts, and uninsured amounts. The balances are in U.S. dollars. The data elements will include:


1 CS_Unique_ID This field is the unique identifier that is the primary key for the depositor data record. It will be generated by the CI and there cannot be duplicates.

Variable Character.

2 DP_Acct_Identifier Deposit account identifier. The primary field used to identify a deposit account. The account identifier may be composed of more than one physical data element to uniquely identify a deposit account.

Variable Character.

3 DP_Right_Capacity Account ownership categories. — SGL - Single accounts — JNT - Joint accounts — REV - Revocable trust accounts — IRR - Irrevocable trust accounts — CRA - Certain retirement accounts — EBP - Employee benefit plan accounts — BUS - Business/Organization accounts — GOV1, GOV2, GOV3 - Government accounts

(public unit accounts) — MSA - Mortgage servicing accounts for principal

and interest payments — DIT - Accounts held by a depository institution

as the trustee of an irrevocable trust — ANC - Annuity contract accounts — PBA - Public bond accounts — BIA - Custodian accounts for American Indians — DOE - Accounts of an IDI pursuant to the Bank

Deposit Financial Assistance Program of the Department of Energy

Character (4).


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4 DP_Prod_Cat Product category or classification. — DDA - Demand Deposit Accounts — NOW - Negotiable Order of Withdrawal — MMA - Money Market Deposit Accounts — SAV - Other savings accounts — CDS - Time Deposit accounts and Certificate of

Deposit accounts, including any accounts with specified maturity dates that may or may not be renewable.

Character (3).

5 DP_Allocated_Amt The current balance in the account at the close of business on the effective date of the file, allocated to a specific owner in that insurance category. — For JNT accounts, this is a calculated field that

represents the allocated amount to each owner in JNT category.

— For REV accounts, this is a calculated field that represents the allocated amount to each beneficial owner in REV category.

— For other accounts with only one owner, this is the account current balance.

This balance shall not be reduced by float or holds. For CDs and time deposits, the balance shall reflect the principal balance plus any interest paid and available for withdrawal not already included in the principal (do not include accrued interest)

Decimal (14, 2).

6 DP_Acc_Int Accrued interest allocated similarly as data field #5 The amount of interest that has been earned but not yet paid to the account as of the date of the file.

Decimal (14, 2).

7 DP_Total_PI Total amount adding #5 DP_Allocated_Amt and #6 DP_Acc_Int.

Decimal (14, 2).

8 DP_Hold_Amount Hold amount on the account. The available balance of the account is reduced by the hold amount. It has no effect on current balance (ledger balance).

Decimal (14, 2).

9 DP_Insured_Amount The insured amount of the account. Decimal (14, 2).

10 DP_Uninsured_Amount The uninsured amount of the account. Decimal (14, 2).

11 DP_Prepaid_Account_Flag This field indicates a prepaid account with CI. Enter "Y" if account is a prepaid account with CI, enter "N" otherwise.

Character (1).

12 DP_PT_Account_Flag This field indicates a pass-through account with CI. Enter "Y" if account is a pass-through with CI, enter "N" otherwise.

Character (1).

13 DP_PT_Trans_Flag This field indicates whether the fiduciary account has sub-accounts that have transactional features. Enter "Y" if account has transactional features, enter "N" otherwise.

Character (1).


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The Account Participant File will be used by the FDIC to identify account participants, to include the official custodian, beneficiary, bond holder, mortgagor, or employee benefit plan participant, for each account and account holder. One record represents one unique account participant. The Account Participant File is linked to the Account File by CS_Unique_ID and DP_Acct_Identifier. The data elements will include:


1 CS_Unique_ID This field is the unique identifier that is the primary key for the depositor data record. It will be generated by the CI and there cannot be duplicates.

Variable Character.

2 DP_Acct_Identifier Deposit account identifier. The primary field used to identify a deposit account. The account identifier may be composed of more than one physical data element to uniquely identify a deposit account.

Variable Character.

3 DP_Right_Capacity Account ownership categories. — SGL - Single accounts — JNT - Joint accounts — REV - Revocable trust accounts — IRR - Irrevocable trust accounts — CRA - Certain retirement accounts — EBP - Employee benefit plan accounts — BUS - Business/Organization accounts — GOV1, GOV2, GOV3 - Government accounts

(public unit accounts) — MSA - Mortgage servicing accounts for principal

and interest payments — DIT - Accounts held by a depository institution

as the trustee of an irrevocable trust — ANC - Annuity contract accounts — PBA - Public bond accounts — BIA - Custodian accounts for American Indians — DOE - Accounts of an IDI pursuant to the Bank


Character (4).

4 DP_Prod_Cat Product category or classification. — DDA - Demand Deposit Accounts — NOW - Negotiable Order of Withdrawal — MMA - Money Market Deposit Accounts — SAV - Other savings accounts — CDS - Time Deposit accounts and Certificate of


Character (3).

5 AP_Allocated_Amount Amount of funds attributable to the account participant as an account holder (e.g. public account holder of a public bond account) or the amount of funds entitled to the beneficiary for the purpose of insurance determination (e.g. Revocable Trust)

Decimal (14, 2).


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6 AP_Participant_ID This field is the unique identifier for the Account Participant. It will be generated by the CI and there shall not be duplicates. If the account participant is an existing bank customer this field is the same as CS_Unique_ID field.

Variable Character.

7 AP_Govt_ID This field shall contain the ID number that identifies the entity based on a government issued ID or corporate filing. Populate as follows: — For a United States individual - Legal

identification number (e.g. SSN, TIN, Driver’s License or Passport Number)

— For a foreign national individual - where a SSN or TIN does not exist, a foreign passport or other legal identification number (e.g. Alien Card)

— For a non-individual - the Tax identification Number (TIN), or other registered entity number

Variable Character.

8 AP_Govt_ID_Type The valid customer identification types, are: — SSN - Social Security Number — TIN - Tax Identification Number — DL - Driver’s License, issued by State or

Territory of the United States

— ML - Military ID — PPT - Valid Passport — AID - Alien Identification Card — OTH – Other

Character (3).

9 AP_First_Name Customer first name. Use only for the name of individuals and the primary contact for entity.

Variable Character.

10 AP_Middle_Name Customer middle name. Use only for the name of individuals and the primary contact for entity.

Variable Character.

11 AP_Last_Name Customer last name. Use only for the name of individuals and the primary contact for entity.

Variable Character.

12 AP_Entity_Name The registered name of the entity. Do not use this field if the participant is an individual.

Variable Character.

13 AP_Participant_Type This field is used as the participant type identifier type: — OC - Official Custodian — BEN - Beneficiary — BHR - Bond Holder — MOR - Mortgagor — EPP - Employee Benefit Plan Participant

Variable Character.


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Pending File

The Pending File contains the information needed for the FDIC to contact the owner or agent requesting additional information to complete the deposit insurance calculation. Each record represents a deposit account. The data elements will include:


1 CS_Unique_ID This field is the unique identifier that is the primary key for the Depositor Data record. It will be generated by the CI and there can be no duplicates.

Variable Character.

2 Pending_Reason Reason code for the account to be included in Pending table. For deposit account records maintained by the CI, use the following codes: — A = need agent (broker, etc.) or custodian

information — B = missing beneficiary information for Trust

Accounts — RAC = missing right and capacity code — OI = missing official item For alternative record keeping requirements, use the following codes: — ARB = direct obligation brokered deposit — ARBN = non-direct obligation brokered deposit — ARCRA = certain retirement accounts — AREBP = employee benefit plan accounts — ARM = mortgage servicing for principal and

interest payments — ARO = other deposits — ARTR = trust accounts The FDIC needs these codes to initiate the collection of needed information post-closing.

Character (5).

3 DP_Acct_Identifier Deposit account identifier. The primary field used to identify a deposit account or official item. The account identifier may be composed of more than one physical data element to uniquely identify a deposit account.

Variable Character.


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4 DP_Right_Capacity Account ownership categories. — SGL = Single accounts — JNT = Joint accounts — REV = Revocable trust accounts — IRR = Irrevocable trust accounts — CRA = Certain retirement accounts — EBP = Employee benefit plan accounts — BUS = Business/Organization accounts — GOV1, GOV2, GOV3 = Government accounts

(public unit accounts) — MSA = Mortgage servicing accounts for

principal and interest payments — DIT = Accounts held by a depository institution

as the trustee of an irrevocable trust — ANC = Annuity contract accounts — PBA = Public bond accounts — BIA = Custodian accounts for American Indians — DOE = Accounts of an CI pursuant to the Bank


Character (4).

5 DP_Prod_Category Product category or classification. — DDA = Demand Deposit Accounts — NOW = Negotiable order of withdrawal — MMA = Money Market Deposit accounts — SAV = Other savings accounts — CDS = Time Deposit accounts and Certificate of


Character (3).

6 DP_Cur_Bal Current balance. The current balance in the account at the close of business on the effective date of the file. This balance should not be reduced by float or holds. For CDs and time deposits, the balance should reflect the principal balance plus any interest paid and available for withdrawal not already included in the principal (do not include accrued interest).

Decimal (14, 2).

7 DP_Acc_Int Accrued interest. The amount of interest that has been earned but not yet paid to the account as of the date of the file.

Decimal (14, 2).

8 DP_Total_PI Total of principal and accrued interest. Decimal (14, 2).

9 DP_Hold_Amount Hold amount on the account. The available balance of the account is reduced by the hold amount. It has no impact on current balance (ledger balance).

Decimal (14, 2).

10 DP_Prepaid_Account_Flag This field indicates a prepaid account with CI. Enter "Y" if account is a prepaid account with CI, enter "N" otherwise.

Character (1).


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11 CS_Govt_ID This field should contain the ID number that identifies the entity based on a government issued ID or corporate filing. It is assumed that the following will be populated: — For a US Individual - Legal identification number

(e.g. SSN, TIN, Driver's License or Passport Number).

— For a Foreign National Individual - where a SSN or TIN doesn't exist a foreign passport or other legal identification number (e.g. Alien Card)

— For a Non-Individual - the Tax identification Number (TIN), or other registered entity number.

Variable Character.

12 CS_Govt_ID_Type The valid customer identification types, are noted below: — SSN = Social Security Number — TIN = Tax Identification Number — DL = Driver's License, issued by State or

Territory of the U.S. — ML = Military ID — PPT = Valid Passport — AID = Alien Identification Card — OTH = Other

Character (3).

13 CS_First_Name Customer first name. Use only for name of individuals, and the primary contact for an entity.

Variable Character.

14 CS_Middle_Name Customer middle name. Use only for name of individuals, and the primary contact for an entity.

Variable Character.

15 CS_Last_Name Customer last name. Use only for name of individuals, and the primary contact for an entity

Variable Character.

16 CS_Name_Suffix Customer suffix such as ‘‘Jr’’ Variable Character.

17 CS_Entity_Name The registered name of the entity, this field should not be used for individual .

Variable Character.

18 CS_Street_Add_Ln1 Street address line 1. The current account statement mailing address of record

Variable Character.

19 CS_Street_Add_Ln2 Street address line 2. If available, the second address line.

Variable Character.

20 CS_Street_Add_Ln3 Street address line 3. If available, the third address line.

Variable Character.

21 CS_City The city associated with the permanent legal address.

Variable Character.


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22 CS_State The state for US Addresses or state/province/county for International Addresses. — For US Addresses use a two-character state

code (official U.S. Postal Service abbreviations) associated with the permanent legal address.

— For international address follow that country state code. Example is two letter abbreviation for provinces in Canada would be used.

Variable Character.

23 CS_ZIP The Zip/Postal Code associated with the customer’s permanent legal address. — For US zip codes, use the U.S. Postal Service

ZIP+4 standard . — For international zip codes, follow that standard

format of that country. Example is UK zip code format that would include letters and numbers.

Variable Character.

24 CS_Country The country associated with the mailing address. Provide the country name or the standard International Organization for Standardization (ISO) country code.

Variable Character.

25 CS_Telephone Customer telephone number. The telephone number on record for the customer, including the country code if not within the United States.

Variable Character.

26 CS_Email The email address on record for the customer. Variable Character.

27 CS_Outstanding_Debt_Flag This field indicates if the customer has outstanding debt with CI, it may be used to help determine an offset. Enter "Y" if customer has outstanding liabilities with CI, enter "N" otherwise.

Character (1).

28 CS_Security_Pledge_Flag This field indicates if the CI has pledged securities to a governmental entity, to cover any shortfall in deposit insurance. Enter "Y" if the government entity has outstanding security pledge with CI, enter "N" otherwise. This field should only be used for Government customers.

Character (1).

29 DP_PT_Account_Flag This field indicates a pass-through account with CI. Enter "Y" if account is a pass-through with CI, enter "N" otherwise.

Character (1).

30 PT_Parent_Customer_ID This field contains the unique identifier of the parent customer ID who has the fiduciary responsibility at the CI. Example is the administrator of an Employee Participant Plan.

Variable Character.

31 DP_PT_Trans_Flag This field indicates if a fiduciary account held at the CI has sub accounts which have transactional features. Enter "Y" if account meets this criteria, enter "N" otherwise.

Character (1).


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Appendix B Explanation of Ownership Account Categories

FDIC deposit insurance coverage is provided for funds owned in different ORCs. All deposits—whether in one account or multiple deposit accounts—held in an insured depository institution in a particular ORC are aggregated and insured up to the SMDIA. An ORC is a legal basis of ownership and is based on federal statutes and FDIC regulations. This section provides high-level summaries of the 14 account ownership categories. If additional information is needed, visit the FDIC site at: https://www.fdic.gov/news/news/financial/2015/fil15038.html for training material, video sessions, and a schedule of live seminars.

Single Account (Code: SGL)

A Single Account (12 CFR §330.6) represents funds owned by one natural person and where no beneficiaries are named. A depositor is entitled to insurance of all funds up to the SMDIA for the aggregate balance of all accounts in the single account category.

Account Title Examples Identification of Single Accounts

— John Doe — Jack Smith as

Administrator of the Estate of Mary Smith (Mary is the owner)

— Jane Jones, Minor, John Jones, Custodian, UGMA (Jane is the owner)

— This category includes funds owned by a Sole Proprietorship or DBA (not insured as a business account).

— This category includes funds established for a deceased person, which are not insured as a revocable trust account.

— This category includes accounts of decedents and accounts held by executors or administrators of a decedent’s estate, Uniform Gift to Minor Accounts, conservatorship and guardianship accounts for the principal, sole proprietorships, as defined in 12 CFR § 330.1.

— If a depositor designates an account as “payable on death” and names beneficiaries, the deposit is not a single account, but a revocable trust account.

— If an account does not qualify for one of the other categories, this is the default insurance category.

https://www.fdic.gov/news/news/financial/2015/fil15038.html


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Joint Account (Code: JNT)

Joint Accounts (12 CFR §330.9) represent funds owned by two or more individuals. Each owner must be a natural person with equal withdrawal rights.

Account Title Examples Identification of Joint Accounts

— John Smith, Mary Smith — John Smith, Mary

Smith, Jack Jones — John Smith and Mary

Smith DBA Smith’s Kitchen

— Corporations, partnerships, associations, trusts and estates are not eligible for this category.

— If two or more depositors designate an account as “payable on death” and name beneficiaries, the deposit is a revocable trust account.

— Each co-owner must sign the signature card. Electronic signatures are acceptable. The signature card requirement is waived for CDs, negotiable instruments, and agency accounts held for joint account owners.

— Adding a name to a joint account for convenience purposes may limit equal withdrawal rights and result in the account not being insured as an account in this category.

Revocable Trust Account (Code: REV)

A Revocable Trust Account (12 CFR §330.10) is a testamentary deposit account owned by one or more people expressing the intent that upon the owner(s)’ death the deposited funds will belong to one or more named beneficiaries. The owner must be a natural person. A revocable trust account can be revoked, terminated or amended at the discretion of the owner(s). The ability to amend a revocable trust account includes the right to change beneficiaries and beneficiary allocations. The FDIC regulations provide for two types of revocable trusts - informal revocable trusts and formal revocable trusts. Informal revocable trusts are often called payable-on death (“POD”), in-trust-for (“ITF”), as trustee for (“ATF”), or Totten trust accounts that are created when an account owner signs an agreement, which is usually part of the CI’s signature card, directing the CI to transfer the funds in the account to one or more named beneficiaries upon the owner’s death. Formal revocable trusts are known as living or family trusts that are written agreements created for estate planning purposes. The owner controls the deposits and other assets in the trust during his or her lifetime. The agreement establishes that the deposits are to be paid to one or more identified beneficiaries upon the owner’s death. The trust generally becomes irrevocable upon the owner’s death. Typically, formal revocable trust agreements will refer to the trust owner as the grantor, settlor, trustor, maker or donor.

Account Title Examples Identification of Revocable Trust Accounts

— Anne Taylor in trust for (ITF) John Taylor, Linda Taylor

— Anne Taylor payable on death (POD) Greg Taylor, Wanda Taylor

— Anne Taylor and John Taylor in trust for Kirk Taylor, Jim Taylor

— The beneficiary must be an eligible beneficiary as defined by: o Natural person (living) o Charity (valid under IRS rules) o Non-profit organization (valid under IRS rules)

— Where the owners of a co-owned revocable trust account are themselves the sole beneficiaries of the corresponding trust, the account shall be insured as a joint account under § 330.9 and shall not be insured under the provisions of this section.

— For purposes of this rule, “account title” includes the electronic deposit account records of the bank.

— The FDIC will recognize the account as a revocable trust account provided the bank’s electronic deposit account records identify the deposit as a POD account. For instance, this designation can be made using a code in the bank’s electronic deposit account records. The actual names of the beneficiaries must be identified in the deposit account records of the CI.


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Irrevocable Trust Account (Code: IRR)

An Irrevocable Trust Account (12 CFR §330.13) is a deposit where the owner indicates an intention that the funds will belong to one or more named beneficiaries upon the last owner’s death. The owner must be an individual/natural person.

— For the purpose of FDIC deposit insurance coverage, irrevocable means that the grantor (person who

created the trust) does not possess the power to terminate or revoke the trust.

— An Irrevocable Trust may be created through:

‒ Death of the grantor of a revocable living trust

‒ Execution or creation of an irrevocable trust agreement

‒ Statute or court order

Account Title Examples Identification of Irrevocable Trust Accounts

— Smith Irrevocable Trust Dated 5-5-2010

— Accounts is evidenced by a formal irrevocable trust agreement

Certain Retirement Accounts (Code: IRA)

In the Certain Retirement Accounts category (12 CFR § 330.14 (b)-(c)), deposits are owned by only one participant. The owner must be an individual/natural person.

Account Title Examples Identification of Certain Retirement Accounts

— John Doe, IRA — ABC Bank as Custodian,

John Doe, IRA account — John Doe, IRA, Mary

Doe beneficiary

— Account must be self-directed (except for Section 457 Plans). o The owner of the plan, not an administrator, has the right to direct how

the funds are invested, including the ability to direct that the funds be deposited at a specific CI.

— Account must be titled in the name of the owner’s self-directed retirement plan.

— Types of accounts in this category include: o Traditional and Roth IRAs (IRAs in non-deposit products are not insured) o Savings Incentive Match Plan for Employees (SIMPLE) IRAs o Simplified Employee Pension (SEP) IRAs o Section 457 deferred compensation plans (whether or not self-directed) o Self-directed defined contribution plans o Self-directed Keogh plans


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Employee Benefit Plan Account (Code: EBP)

Employee Benefit Plan Accounts (12 CFR §330.14) are deposits held by any plan that satisfies the definition of an employee benefit plan in section 3(3) of the Employee Retirement Income Security Act of 1974 (“ERISA”), except for those plans that qualify under Certain Retirement Accounts category. Owner must be the employee benefit plan itself, and the beneficial owners are the participants.

Account Title Examples Identification of Employee Benefit Plan Accounts

— Brotherhood of Electrical Workers Health and Welfare

— AT&T Employee Profit Sharing Plan

— Johnson Law Offices, P.C. Defined Benefit Plan

— The account title must indicate the existence of an employee benefit plan. — The plan administrator must be prepared to produce copies of the plan

documents. — Types of accounts insured in this category include:

o All defined benefit plans. o Defined contribution plans, including profit-sharing plans and 401(k)

plans that do not qualify as “self-directed” plans.

Business/Organization Account (Code: BUS)

Business/Organization Accounts (12 CFR §330.11) represent funds owned by a business or an organization. The owner must be a legally created business or organization--a corporation, partnership, or unincorporated association.

Account Title Examples Identification of Business Accounts

— Smith and Jones, Limited Liability Corporation (LLC)

— Smith Orthopedists, Professional Corporation (PC)

— Family Church of Maintown

— Based on state law, the business/organization must be a legally created entity: o Corporation (includes Subchapter S, LLCs, and PCs) o Partnership o Unincorporated Association

— The business/organization must be engaged in an independent activity, which means the entity was formed for a business reason and not solely to increase deposit insurance coverage. Independent activity is generally supported by: o Separate tax identification numbers o Separate charter or bylaws

— This category does not include sole proprietorships (as indicated in the single accounts category; these are single accounts) or unincorporated partnerships

— The existence of multiple signers such as partners, officers or directors does not increase coverage.

— A separate business purpose for funds owned by the same legal entity does not increase coverage.


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Government Account (Code: GOV1, GOV2, GOV3)

Government Accounts (12 CFR §330.15) are funds placed by an official custodian of a government entity, including a federal, state, county, municipal entity, or political subdivision. The owner must be a government entity. For the Government Accounts Category, the insured party is the “official custodian”– an appointed or elected official who has “plenary authority” over funds in the account owned by the public unit.

Account Title Examples Identification of GOV1, GOV2, and GOV2 Government Accounts

GOV1 examples: government time and savings account titles (in these examples, the CI is chartered or has branches in the State of California): — State of California,

Treasurer’s Office (CD) — City of Los Angeles,

Police Department (MMA)

— City of Sacramento, Fire Department (NOW)

— The code GOV1 must be used to identify all time and savings deposit accounts of the U.S. and all time and savings deposit accounts of a state, county, municipality or political subdivision depositing funds in a CI in the state comprising the public unit or wherein the public unit is located (including any CI having a branch in said state).

GOV2 examples: government demand deposit account titles (in these examples, the CI is chartered or has branches in the State of California): — City of San Francisco

DDA — State of California

Department of Revenue (DDA)

— County of Los Angeles Fire Department (DDA)

— The code GOV2 must be used to identify all demand deposit accounts of the U.S. and all demand deposit accounts of a state, county, municipality or political subdivision depositing funds in a CI in the state comprising the public unit or wherein the public unit is located (including any CI having a branch in said state).

GOV3 examples: government account titles (in these examples, the CI is not chartered in Alaska and does not have branches in Alaska): — City of Fairbanks,

Alaska, Police Department

— State of Alaska, State Treasurer

— Anchorage, Alaska Public Library

— The code GOV3 must be used to identify all deposits, regardless of whether they are time, savings or demand deposit accounts of a state, county, municipality or political subdivision depositing funds in a CI outside of the state comprising the public unit or wherein the public unit is located.


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Mortgage Servicing Account (Code: MSA)

Mortgage Servicing Accounts (12 CFR §330.7(d)) are established by mortgage servicers and represent commingled principal and interest payments received from borrowers. The owner must be a mortgage servicer.

Account Title Examples Identification of Mortgage Servicing Accounts

— ABC Bank as servicer for FNMA

— Accounts established by mortgage servicers

Public Bonds Account (Code: PBA)

A Public Bonds Account (12 CFR §330.15(c)) represents funds which by law or under a bond indenture are required to be set aside to discharge a debt owed to the holders of notes or bonds issued by a public unit. The owner must be a government entity.

Account Title Examples Identification of Public Bonds Accounts

— City of Los Angeles, Debt Service Account

— Collin County Municipal Water and Utility, Municipal Bond

— The deposit account must satisfy certain disclosure requirements applicable to deposits held by agents or fiduciaries: o The deposit account records of the CI must disclose the existence of the

fiduciary relationship or the fiduciary nature of the deposit. o The details of the fiduciary relationship and the interests of the

bondholders must be ascertainable from the records of the CI or the records of the depositor maintained in good faith and in the regular course of business.

Irrevocable trust account with an insured depository institution as trustee (Code: DIT)

An Irrevocable Trust Account with a CI as trustee (12 CFR §330.12) represents trust funds held by a CI in its capacity as trustee of an irrevocable trust.

Account Title Examples Identification of Irrevocable Trust Accounts with a CI as Trustee

— ABC Bank as trustee of the Jones Family Irrevocable Trust

— As set forth in 12 CFR §330.12

Annuity Contract Account (Code: ANC)

An Annuity Contract Account (12 CFR §330.8) represents funds held by an insurance company or other corporation in a deposit account for the sole purpose of funding life insurance or annuity contracts and any benefits linked to the contracts.

Account Title Examples Identification of Annuity Contract Accounts

— Allstate Insurance Company, annuity contract for Jack Smith and Mary Smith

— CAN Insurance Company, annuitant account

— An account may be covered under this category, provided that, pursuant to a state statute: o The insurance company establishes a separate account for the funds; o The account cannot be charged with the liabilities arising out of any other

business of the insurance company; and o The account cannot be invaded by other creditors of the insurance

company in the event that the insurance company becomes insolvent and its assets are liquidated.


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Account of a CI pursuant to Bank Deposit Financial Assistance Program of the Department of Energy (Code: DOE)

This category consists of (12 U.S.C. 1817 (i) (3)) funds deposited by a CI pursuant to the Bank Deposit Financial Assistance Program (BDFAP) of the Department of Energy.

Account Title Examples Identification of Accounts of a CI pursuant to BDFAP of the Department of Energy

— ABC Bank under the BDFAP for the Department of Energy

— Third Bank of California under the BDFAP

— As set forth in 12 U.S.C. 1817 (i) (3).

Custodian Account for American Indians (Code: BIA)

A Custodian Account for American Indians (12 CFR § 330.7(e)) represents funds held on behalf of an individual American Indian deposited by the Bureau of Indian Affairs of the U.S. Department of the Interior pursuant to 25 USC 162(a).

Account Title Examples Identification of Custodian Accounts for American Indians

— Bureau of Indian Affairs as agent for [Name]

— As set forth in 12 CFR § 330.7(e).

FDIC – Part 370 Recordkeeping Algorithm – Use Case Scenarios Version 1.0

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Appendix C Use Cases

The following sections provide a series of sample use cases that are intended to demonstrate example deposit insurance determination scenarios and assist the CI with the development of its IT systems in compliance with 12 CFR Part 370.


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C.1 Single Accounts

C.1.1 Scenario 1

C.1.1.1 Background

Marci Jones has two separate deposit accounts at a CI. The first is a savings account in her name alone for $55,000 and the second is her unincorporated business account (operating as a sole proprietorship) for $25,000. Marci Jones also placed $200,000 in a CD account at the CI. All three accounts are assigned correctly by the CI the Single Account right and capacity for purposes of deposit insurance determination.

Account Title Owner Deposit Type Total Balance

Marci Jones Marci Jones Savings $55,000

Marci Jones DBA Marci's Cakes (a sole proprietorship) Marci Jones DDA $25,000

Marci Jones Marci Jones CD $200,000

Total

$280,000

Assume for simplicity all the amounts above represent the outstanding balance of each account (i.e., no accrued interest).

C.1.1.2 Algorithm Application


Marci Jones is the account owner for all three single accounts.

2) Aggregate total account balance and accrued interest by each unique account owner for all accounts held by the owner in the Single Account right and capacity at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balance and accrued interest is $280,000 for all accounts Marci Jones holds in the SGL right and capacity.



Not applicable, total balance25

of $280,000 exceeds SMDIA.


Total balance of $280,000 exceeds SMDIA by $30,000 and the excess of $30,000 is the uninsured amount.



Not applicable.

25

For purposes of this document, total balance is inclusive of total account balance and accrued interest, unless otherwise stated.


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b) If there is an uninsured amount remaining after step a, determine the owner’s single account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Based on the Liquidity Priority Order, the uninsured funds of $30,000 will be applied to Marci Jones’ CD account.

c) If post step b, there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.

Not applicable.

d) If post step c, there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

Not applicable.


Record an uninsured balance of $30,000 under the Uninsured Amount field in the Account File for Marci Jones’ CD account

For the other two accounts, the uninsured amount is zero

Account Title Uninsured Amount

Marci Jones $0

Marci Jones DBA Marci's Cakes (a sole proprietorship) $0

Marci Jones’ CD $30,000

Total $30,000


For each account, the insured amount is equal to the difference between the total balance and the uninsured amount.

Record the following insured amounts for the three accounts under the Insured Amount fields in the Account File.

Account Title Insured Amount

Marci Jones $55,000

Marci Jones DBA Marci's Cakes (a sole proprietorship) $25,000

Marci Jones’ CD $170,000

Total $250,000


Flag all three accounts as complete after the steps above are completed.

C.1.1.3 Outcome

One entry in the Customer File for Marci Jones.


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Three entries in the Account File: one for each of three accounts Marci Jones has under the SGL right and capacity.

No entry in the Account Participant File.

No entry in the Pending File as information is available to complete the insurance determination.

C.1.2 Scenario 2

C.1.2.1 Background

Beatrice Allen has two single deposit accounts at a CI. The first is a CD account in her name alone for $200,000, $5,000 of which represents accrued interest and the second is a CD for $40,000, $1,000 of which represents accrued interest. Beatrice also has an account maintained by her mortgage service provider, Pleasant Hill Mortgage Servicing, containing $20,000 in taxes and insurance payments. Assume the mortgage loan Beatrice Allen has outstanding with the mortgage servicer is originated by the CI.

Account Title Owner Deposit Type Total Balance Accrued Interest

Beatrice Allen’s CD Account – 1 Beatrice Allen CD $200,000 $5,000

Beatrice Allen’s CD Account – 2 Beatrice Allen CD $40,000 $1,000

Pleasant Hill Mortgage Servicing T&I of Beatrice Allen Beatrice Allen DDA $20,000 $0

Total $260,000 $6,000



Beatrice Allen is the account owner for all funds deposited in these three accounts.

The taxes and insurance payment maintained by the mortgage servicer represents a fiduciary account and the balance of $20,000 represents funds Beatrice Allen holds in the single account right and capacity.

2) Aggregate total account balance and accrued interest by each unique account owner for all accounts the owner holds in the Single Account right and capacity at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balance and accrued interest is $260,000 for all accounts Beatrice Allen holds in the SGL right and capacity.



Not applicable, total balance of $260,000 exceeds SMDIA.





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Applicable as there is an uninsured amount of $10,000 for Beatrice Allen.


Apply uninsured amount of $5,000 to Beatrice Allen’s first CD account with $5,000 in accrued interest.

Apply uninsured amount of $1,000 to Beatrice Allen’s second CD account with $1,000 in accrued interest.


Based on the Liquidity Priority Order, the remaining uninsured funds of $4,000 will be applied to either of Beatrice Allen’s CD accounts.

c) If after step b, there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.

Apply remaining uninsured funds of $4,000 to Beatrice Allen’s first CD account as it has a higher total balance.

d) If after step c, there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

Not applicable.


Record the following uninsured amounts for the three accounts under the Uninsured Amount field in the Account File:


Beatrice Allen’s CD Account – 1 $9,000


Pleasant Hill Mortgage Servicing T&I of Beatrice Allen $0

Total $10,000


Record the following insured amounts for the three accounts under the Insured Amount field in the Account File:




Pleasant Hill Mortgage Servicing T&I of Beatrice Allen $20,000

Total $250,000




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C.1.2.3 Outcome

Two entries in the Customer File: one for Beatrice Allen and one for the mortgage service provider, Pleasant Hill Mortgage Servicing.

As Beatrice Allen has an outstanding mortgage loan with the CI, set CS_Outstanding_Debt_Flag = Y.

Four entries in the Account File:

One for each of three accounts Beatrice Allen has under the SGL right and capacity.

One entry representing the pass through account with the mortgage service provider. Set Right and Capacity = Null and DP_PT_Account_Flag = Y.




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C.2 Joint Accounts

C.2.1 Scenario 1

C.2.1.1 Background

Mary and John Smith co-own an unincorporated business, Smith’s Apple Pies. They opened a joint DBA account at a CI to keep track of their funds. They have equal withdrawal rights and each signed the signature card. At the same CI, Mary and Robert Smith have a joint savings account. Mary, John and Robert also co-own a CD account and all of them have equal withdrawal rights.

Account Title Deposit Type Total Balance

Mary Smith or John Smith DBA Smith's Apple Pies DDA $230,000

Robert Smith or Mary Smith Savings $250,000

Mary Smith or John Smith or Robert Smith CD $270,000

Total

$750,000

Assume for simplicity all the amounts above represent the outstanding total balance of each account (i.e., no accrued interest).


1) Identify all unique joint account co-owners.

Joint account co-owners include Mary Smith, John Smith, and Robert Smith.

2) Aggregate total account balance and accrued interest for each unique account owner for those accounts held in the JNT right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balance and accrued interest is $330,000, $205,000, and $215,000 allocated for Mary Smith, John Smith, and Robert Smith respectively.

Account Title Mary Smith John Smith Robert Smith Total Balance

Mary Smith or John Smith DBA Smith's Apple Pies $115,000 $115,000 $0 $230,000

Robert Smith or Mary Smith $125,000 $0 $125,000 $250,000

Mary Smith or John Smith or Robert Smith $90,000 $90,000 $90,000 $270,000

Total $330,000 $205,000 $215,000 $750,000


a) If the total balance and accrued interest of an account owner does not exceed SMDIA, then the funds of the account owner across all joint accounts at the CI are fully insured.

Not applicable for Mary Smith as her aggregate total balance does exceed SMDIA.

Applicable for Robert Smith and John Smith as their respective aggregate total balance does not exceed SMDIA and their respective funds are fully insured.


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Joint Account Owner Allocation Insured Amount Uninsured Amount

John Smith $205,000 $205,000 $0

Robert Smith $215,000 $215,000 $0

Total $420,000 $420,000 $0

b) If the total balance and accrued interest of an account owner exceeds SMDIA, then the owner’s funds in excess of SMDIA are not insured. If there are uninsured funds, then:

Applicable for Mary Smith as her aggregate total balance does exceed SMDIA and the excess is the uninsured amount.


Mary Smith $330,000 $250,000 $80,000

Total $330,000 $250,000 $80,000

c) Determine the uninsured amount for each account owner based on steps 3a and 3b above.

Based on the above two steps, the uninsured amount for each of the three account owners is as follows:


Mary Smith $330,000 $250,000 $80,000

John Smith $205,000 $205,000 $0

Robert Smith $215,000 $215,000 $0

Total $750,000 $670,000 $80,000

4) If there is an uninsured amount for an account owner:

Applicable to Mary Smith as she has uninsured amount.

Not applicable to Robert Smith and John Smith as their funds are fully insured.

a) Determine the allocation ratio for each owner with uninsured funds by dividing the owner’s uninsured amount by the owner’s aggregate total balance.

For Mary Smith, the allocation ratio for uninsured funds is calculated as follows:

Joint Account Owner Uninsured Amount Total Balance Allocation Ratio26

Mary Smith $80,000 $330,000 24.24%=$80,000/$330,000

b) Apply the uninsured amount first to the accrued interest (if any) of all such accounts.

Not Applicable as there is no accrued interest in any of these three accounts.

c) If there is an uninsured amount remaining after step b, allocate remaining uninsured funds of each owner based on the allocation ratio calculated above across all such accounts.

26

For the purposes of this document, the percentage has been rounded to two decimal places.


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Allocate the $80,000 uninsured funds for Mary Smith across these three accounts as follows:

Account Title

Mary Smith

Balance (A)

Mary Smith Allocation

Ratio (B)

Mary Smith Uninsured

Amount (A*B)

Mary Smith or John Smith DBA Smith's Apple Pies

$115,000 24.24% $27,879

Robert Smith or Mary Smith $125,000 24.24% $30,303

Mary Smith or John Smith or Robert Smith $90,000 24.24% $21,818

Total $330,000 $80,000

d) EACH DEPOSITOR IS ENTITLED TO INSURANCE UP TO THE SMDIA IN EACH ORC. DUE TO THE JOINT OWNERSHIP NATURE OF THIS ORC, EACH DEPOSITOR IS SUBJECT TO DEPOSIT INSURANCE COVERAGE LIMITS ON AN INDIVIDUAL BASIS BUT THE DEBITS ARE APPLIED ON AN ACCOUNT LEVEL.

5) Based on the above determination (and repeat as necessary for each account owner), determine and record the

respective uninsured amount for each account of the account owner.

Record the following uninsured amounts for Mary Smith, John Smith and Robert Smith in the Account File under the Uninsured Amount fields based on results from step 4:

Account Title Account Owner Uninsured Amount

Mary Smith or John Smith DBA Smith's Apple Pies Mary Smith $27,879

Mary Smith or John Smith DBA Smith's Apple Pies John Smith $0

Robert Smith or Mary Smith Mary Smith $30,303

Robert Smith or Mary Smith Robert Smith $0

Mary Smith or John Smith or Robert Smith Mary Smith $21,818

Mary Smith or John Smith or Robert Smith John Smith $0

Mary Smith or John Smith or Robert Smith Robert Smith $0

Total

$80,000

For John Smith and Robert Smith, their respective uninsured amount is $0 as determined in step 3.

6) The insured amount of the owner for each individual account is the difference between the owner’s funds in that account and the uninsured amount determined based on the steps above.


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Record the following insured amounts for Mary Smith, Robert Smith and John Smith in the Account File under the Insured Amount field:

Account Title Account Owner Insured Amount

Mary Smith or John Smith DBA Smith's Apple Pies Mary Smith $87,121

Mary Smith or John Smith DBA Smith's Apple Pies John Smith $115,000

Robert Smith or Mary Smith Mary Smith $94,697

Robert Smith or Mary Smith Robert Smith $125,000

Mary Smith or John Smith or Robert Smith Mary Smith $68,182

Mary Smith or John Smith or Robert Smith John Smith $90,000

Mary Smith or John Smith or Robert Smith Robert Smith $90,000

Total

$670,000

For Robert Smith and John Smith, their respective total balance is fully insured.


Flag all three accounts as complete as the steps above are completed.

C.2.1.3 Outcome

Three (3) entries in the Customer File: one for each account co-owner Mary Smith, John Smith and Robert Smith.

Seven (7) entries in the Account File and each corresponds to a unique combination of account owner and account:

Two (2) entries for the DBA account: Mary Smith and John Smith.

Two (2) entries for the savings account: Mary Smith and Robert Smith.

Three (3) entries for the CD account: Mary Smith, John Smith and Robert Smith.




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C.3 Revocable Trust Accounts

C.3.1 Scenario 1

C.3.1.1 Background

Harry Smith is the owner of two revocable trust accounts held in non-interest bearing DDAs at a CI. The first of which is a POD account designating Harry’s four children (Alan Smith, Betty Smith, Chris Smith, Dawn Smith) as beneficiaries. The POD account has a balance of $1,000,000. Harry’s second trust account is a formal revocable trust with a total balance of $1,500,000. The formal trust provides that upon Harry’s death, the trust assets are to be divided and distributed so that each of his two grandchildren (Eve Smith and Gene Smith) receive a 40% share, the Smith Foundation, an Internal Revenue Service (the “IRS”) recognized non-profit, receives a 15% share, and S.E. Smith, Inc., a for-profit entity, receives a 5% share. Assume these two accounts are the only two accounts Harry Smith has at the CI.

Harry Smith Revocable POD Trust

Beneficiary Beneficiary Allocation

Alan Smith 25%

Betty Smith 25%

Chris Smith 25%

Dawn Smith 25%

Total 100%

Harry Smith Formal Revocable Trust


Eve Smith 40%

Gene Smith 40%

The Smith Foundation 15%

S.E. Smith, Inc. 5%

Total 100%



Harry Smith is the account owner for both trusts.

All children and grandchildren are eligible beneficiaries. As an IRS recognized non-profit, the Smith Foundation is an eligible beneficiary. S.E. Smith, Inc. is a for-profit entity and not recognized as an eligible beneficiary. None of the beneficiaries identified is a contingent beneficiary.


Harry Smith is the only account owner and has seven eligible unique primary beneficiaries: Alan Smith, Betty Smith, Chris Smith, Dawn Smith, Eve Smith, Gene Smith, and the Smith Foundation.

Funds attributed to S.E. Smith, Inc. will be treated as the funds in the single account right and capacity for Harry Smith (See Section 4.1 of this document for SMDIA Determination).


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3) Determine the allocations from each account owner to the eligible unique primary beneficiaries based on the information of the allocation of funds (note a life estate beneficiary is valued at $250,000 for purpose of deposit insurance determination).

Based on the beneficiary allocation information presented in the trust documentation, Harry’s seven eligible unique primary beneficiaries are allocated the following:

Eligible Beneficiary Beneficiary Allocation

Alan Smith $250,000

Betty Smith $250,000

Chris Smith $250,000

Dawn Smith $250,000

Eve Smith $600,000

Gene Smith $600,000

The Smith Foundation $225,000

Total $2,425,000

Funds attributed to the ineligible beneficiary are treated as the funds Harry Smith has in the single account right and capacity.

Ineligible Beneficiary Beneficiary Allocation

S.E. Smith, Inc. $75,000


The aggregate total balance and accrued interest is $2,425,000 for all accounts in the REV Right and Capacity owned by Harry Smith. This is the sum of eligible beneficiary allocations determined in Step 3.


Not applicable as Harry Smith has seven eligible unique beneficiaries.


Not applicable.


Not applicable.


Applicable; Harry Smith has seven eligible unique beneficiaries associated with his accounts with an unequal distribution of interests. Unequal interest is seen in the beneficiary allocations determined in Step 3.


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a) Determine the insured and uninsured amount for the funds associated with each beneficiary based on the aggregate dollar allocation from each account owner to each eligible unique beneficiary as determined above in Step 3 by following the rules below:


Not applicable. Actual beneficiary allocations to the two grandchildren (Eve Smith and Gene Smith) exceed $250,000.


Not applicable. Harry Smith does not have life estate beneficiary.

iii) If any beneficiary interest exceeds SMDIA, then the owner is insured for the greater of (a) the sum of each beneficiary’s share of the trust deposit up to SMDIA for each beneficiary, or (b) $1,250,000.

The insured amount is $1,725,000, the greater of the sum of all beneficiaries’ insured amounts of $1,725,000 or $1,250,000.

Based on the allocations of the funds to each of the seven eligible unique primary beneficiaries as determined in step 3 above, determine the insured and uninsured amount as the following:

Beneficiary Beneficiary Allocation Insured Amount Uninsured Amount

Alan Smith $250,000 $250,000 $0

Betty Smith $250,000 $250,000 $0

Chris Smith $250,000 $250,000 $0

Dawn Smith $250,000 $250,000 $0

Eve Smith $600,000 $250,000 $350,000

Gene Smith $600,000 $250,000 $350,000

The Smith Foundation $225,000 $225,000 $0

Total $2,425,000 $1,725,000 $700,000

Harry Smith is insured for $250,000 for the beneficial interest of each of his children and grandchildren and for $225,000 for the beneficial interest of the Smith Foundation.


Total balance of $2,425,000 exceeds insurance coverage of $1,725,000 by $700,000. Harry Smith’s total insured balance is $1,725,000. Harry Smith has an uninsured balance of $700,000. See the table above.

7) For funds the owner has in a right and capacity other than REV, aggregate the funds the owner has at the CI across all accounts under that right and capacity (if necessary) and determine the deposit insurance based on the algorithm prescribed for that right and capacity.

Applicable as Harry Smith has $75,000 in the SGL right and capacity. Refer to step 3 for details.

As Harry Smith does not have any other accounts at the CI in the SGL right and capacity and his total funds of $75,000 do not exceed $250,000, the funds are therefore fully insured in the SGL right and capacity.


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8) If there are uninsured funds for the owner in either the REV or other right and capacity, then:

Applicable as Harry Smith has an uninsured amount of $700,000 in the REV right and capacity.

Not applicable for the funds Harry Smith has in the SGL right and capacity as the total funds are fully insured.


Not applicable as there is no accrued interest in either of these two accounts.

b) If there is an uninsured amount remaining after step a, determine the owner’s account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Both trust accounts are CDs and allocation cannot be determined based on the liquidity priority order.


The total uninsured funds of $700,000 should be applied to Harry Smith Formal Revocable Trust given its higher balance.


Not applicable as there are no uninsured funds remaining after step c.


For the $75,000 from the Formal Revocable Trust account in the SGL right and capacity, record an uninsured balance of $0 under the Uninsured Amount field in the Account File.

For the POD account, record an uninsured balance of $0 under the Uninsured Amount field in the Account File.

For the $1,425,000 from the Formal Revocable Trust account in the REV right and capacity, record an uninsured balance of $700,000 under the Uninsured Amount field in the Account File.

Account Right and Capacity Total Balance Uninsured Amount

Harry Smith Formal Revocable Trust SGL $75,000 $0

Harry Smith Revocable POD Trust REV $1,000,000 $0

Harry Smith Formal Revocable Trust REV $1,425,000 $700,000

Total $2,500,000 $700,000


The insured amount is the difference between the total balance and the uninsured amount as determined in step 9 above.

For the POD account, record an insured balance of $1,000,000 under the Insured Amount field in the Account File.


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For the Formal Revocable Trust account:

Record an insured balance of $75,000 in the SGL right and capacity under the Insured Amount field in the Account File.

Record an insured balance of $725,000 in the REV right and capacity under the Insured Amount field in the Account File.

Account Right and Capacity Total Balance Insured Amount

Harry Smith Revocable POD Trust REV $1,000,000 $1,000,000

Harry Smith Formal Revocable Trust SGL $75,000 $75,000

Harry Smith Formal Revocable Trust REV $1,425,000 $725,000

Total $2,500,000 $1,800,000


Flag both accounts as complete once the steps above are completed.

C.3.1.3 Outcome

One entry in the Customer File representing Harry Smith.

Three entries in the Account File:

Harry Smith Revocable POD Trust account.

Harry Smith’s interest from the Formal Revocable Trust account in the REV right and capacity.

Harry Smith’s interest from the Formal Revocable Trust account in the SGL right and capacity. The DP_Allocated_Amount of which is equal to $75,000 or the 5% beneficiary percentage allocation of the $1,500,000 original balance of the Harry Smith Formal Revocable Trust.

Seven entries in the Account Participant File each representing one of the seven eligible unique beneficiaries of Harry Smith’s two trust accounts.

No entry in the Pending File as complete information is available for purposes of the insurance determination.

C.3.2 Scenario 2

C.3.2.1 Background

Marsha McDonald is the owner of a POD trust account at a CI and the account designates five beneficiaries with equal distribution of assets. The account is held in a CD and has a balance of $875,000, $15,000 of which represents accrued interest. Beneficiaries include three living family members (Andrew McDonald, Barbara McDonald, and Curtis McDonald) and two IRS recognized non-profit entities (the McDonald Foundation and the Smith Foundation) owned solely by Marsha McDonald. Marsha McDonald does not have any other account with the CI.


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Beneficiary

Andrew McDonald

Barbara McDonald

Curtis McDonald

The McDonald Foundation

The Smith Foundation


1) Identify the account owners and unique eligible primary beneficiaries.

Marsha McDonald is the account owner.

All three family members are eligible primary beneficiaries. As IRS-recognized non-profit entities solely owned by Marsha McDonald, the McDonald Foundation and the Smith Foundation are eligible primary beneficiaries.


Marsha McDonald is the only account owner and has five eligible unique beneficiaries: Andrew McDonald, Barbara McDonald, Curtis McDonald, the McDonald Foundation and the Smith Foundation.

3) Determine the allocations to the eligible unique primary beneficiaries based on the information of the allocation of funds (note a life estate beneficiary is valued at $250,000 for purposes of deposit insurance determination).

Based on the beneficiary allocation information presented in the trust documentation, Marsha’s five eligible unique primary beneficiaries are allocated the following:


Andrew McDonald $175,000

Barbara McDonald $175,000

Curtis McDonald $175,000

The McDonald Foundation $175,000

The Smith Foundation $175,000

Total $875,000

4) Determine the aggregate funds each account owner has across all revocable trust accounts at the CI allocated to the eligible unique primary beneficiaries. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balance and accrued interest is $875,000 for all accounts in the REV right and capacity owned by Marsha McDonald. This is the sum of eligible beneficiary allocations determined in step 3.


Applicable. Marsha McDonald has five eligible beneficiaries associated with her account with an equal distribution of interests. This can be seen in the beneficiary allocations determined in Step 3.


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As the total funds of $875,000 are less than five times $250,000 ( $1,250,000), Marsha McDonald’s total funds of $875,000 in the REV right and capacity are fully insured.


Andrew McDonald $175,000 $175,000 $0

Barbara McDonald $175,000 $175,000 $0

Curtis McDonald $175,000 $175,000 $0

The McDonald Foundation $175,000 $175,000 $0

The Smith Foundation $175,000 $175,000 $0

Total $875,000 $875,000 $0

Note: the above table is presented for illustration purposes only. In this case, such a table does not need to be created for purposes of insurance determination as the uninsured amount can be determined for Marsha McDonald based on a simple comparison of $875,000 and $1,250,000.


Not applicable.


Not applicable.

a) Determine the insured and uninsured amounts for the funds associated with each beneficiary based on the aggregate dollar allocation from each account owner to each eligible unique beneficiary as determined above in Step 3 by following the rules below:


Not applicable.


Not applicable.


Not applicable.


Not applicable.


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Not applicable as Marsha McDonald does not have any funds in a right and capacity other than REV.


Not applicable as Marsha McDonald does not have any uninsured funds.


Not applicable as there is no uninsured amount.


Not applicable.


Not applicable.

d) If post steps c, there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

Not applicable.


Record an uninsured balance of $0 under the Uninsured Amount field in the Account File for Marsha McDonald’s Revocable POD Trust account.

Account Uninsured Amount

Marsha McDonald Revocable POD Trust $0


Record an insured balance of $875,000 under the Insured Amount field in the Account File for Marsha McDonald Revocable POD Trust account.

Account Insured Amount

Marsha McDonald Revocable POD Trust $875,000


Flag the account as complete once the steps above are completed.

C.3.2.3 Outcome

One (1) entry in the Customer File representing Marsha McDonald.


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One (1) entry in the Account File representing Marsha McDonald’s interest in the REV right and capacity.

Five (5) entries in the Account Participant File representing each eligible unique beneficiary of the Marsha McDonald Revocable POD Trust account.

No entry in the Pending File as complete information is available for purpose of the insurance determination.

C.3.3 Scenario 3

C.3.3.1 Background

Ten days after the processing of Marsha McDonald’s Revocable POD Trust Account as described in Section C.3.2 above, the CI identified another trust account for Marsha McDonald, Marsha McDonald Formal Revocable Trust account. The Formal Revocable Trust account is held in a non-interest bearing DDA account with a total balance of $925,000 and names two beneficiaries with equal allocation, Andrew McDonald and the Jones Foundation , an IRS-recognized non-profit entity solely owned by Marsha McDonald. For simplicity, assume there is no accrued interest in the Formal Revocable Trust account.

Beneficiary

Andrew McDonald

The Jones Foundation

Recall the Marsha McDonald Revocable POD Trust account was held as a CD and had five beneficiaries, each allocated an equal share of the account’s interest. The total amount of $875,000 from the POD trust account was fully insured based on the insurance determination as described in Section C.3.2.


1) Identify the account owners and eligible unique primary beneficiaries.

Marsha McDonald is the account owner of both accounts.

Eligible beneficiaries now include all five eligible and unique beneficiaries from the Marsha McDonald Revocable POD Trust Account as well as the Jones Foundation.

Note Andrew McDonald is named as beneficiary for both accounts and is counted as one unique beneficiary for Marsha McDonald for purposes of the insurance determination.

Eligible Beneficiary Marsha McDonald Revocable POD Trust Marsha McDonald Formal Revocable Trust

Andrew McDonald

Barbara McDonald

Curtis McDonald

The McDonald Foundation




Marsha McDonald is the only account owner and has six eligible unique beneficiaries: Andrew McDonald, Barbara McDonald, Curtis McDonald, the McDonald Foundation, the Smith Foundation, and the Jones Foundation.


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Based on the beneficiary allocation information presented in the trust documentation, Marsha’s six eligible unique primary beneficiaries are allocated the following funds:

Eligible Beneficiary Marsha McDonald

Revocable POD Trust

Marsha McDonald Formal Revocable

Trust

Total

Andrew McDonald $175,000 $462,500 $637,500

Barbara McDonald $175,000 $0 $175,000

Curtis McDonald $175,000 $0 $175,000

The McDonald Foundation $175,000 $0 $175,000

The Smith Foundation $175,000 $0 $175,000

The Jones Foundation $0 $462,500 $462,500

Total $875,000 $925,000 $1,800,000


The aggregate total balance and accrued interest is $1,800,000 for all accounts in the REV right and capacity owned by Marsha McDonald.

Note the aggregate total funds include both Marsha McDonald’s Revocable POD Trust account and the newly identified Formal Revocable Trust account.


Not applicable.


Not applicable.


Not applicable.

6) If the total number of eligible unique beneficiaries of an account owner is six or more and all the beneficiaries do not have equal interest in the trust accounts, then:

Applicable., Marsha McDonald has six eligible unique beneficiaries associated with her accounts with an unequal distribution of interests. Unequal interest is seen in the beneficiary allocations determined in step 3.


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a) Determine the insured and uninsured amount for the funds associated with each beneficiary based on the aggregate dollar allocation from each account owner to each eligible unique beneficiary as determined above in step 3 by following the rules below:


Not applicable. Actual beneficiary allocations to Andrew McDonald and the Jones foundation exceed $250,000.

Based on the allocations of the funds to each of the six eligible unique primary beneficiaries as determined in step 3 above, determine the insured and uninsured amount as in the following steps.


Not applicable.

iii) If any beneficiary’s interest exceeds SMDIA, then the owner is insured for the greater of (a) the sum of each beneficiary’s share of the trust deposit up to SMDIA for each beneficiary, or (b) $1,250,000.

Marsha McDonald is insured for $250,000 for the beneficial interest of Andrew McDonald and the Jones Foundation and $175,000 for the beneficial interest of Barbara McDonald, Curtis McDonald, the McDonald Foundation, and the Smith Foundation, respectively.

The total insured amount for Marsha McDonald is $1,250,000, the greater of $1,200,000 or $1,250,000. See the table below for the calculation of the insured amount of $1,200,000 (before comparing it to $1,250,000):

Beneficiary Beneficiary Allocation Insured Amount

Andrew McDonald $637,500 $250,000

Barbara McDonald $175,000 $175,000

Curtis McDonald $175,000 $175,000

The McDonald Foundation $175,000 $175,000

The Smith Foundation $175,000 $175,000

The Jones Foundation $462,500 $250,000

Total $1,800,000 $1,200,000


Total balance of $1,800,000 exceeds insurance coverage of $1,250,000 by $550,000. Marsha McDonald’s total insured balance is $1,250,000.

Marsha McDonald has an uninsured balance of $550,000.


Not applicable as Marsha McDonald does not have any funds in a right and capacity other than REV.


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Applicable as there is an uninsured amount of $550,000 for Marsha McDonald in the REV right and capacity.

a) Apply the uninsured amount to the accrued interest (if any) of all such accounts.

Apply an uninsured amount of $15,000 to Marsha McDonald’s Revocable POD Trust account with $15,000 in accrued interest.


Based on the liquidity priority order, apply the remaining uninsured amount of $535,000 to Marsha McDonald’s Revocable POD Trust account (i.e., the funds in her Formal Revocable Trust account are fully insured).


Not applicable.


Not applicable.


Record an uninsured balance of $550,000 for Marsha McDonald’s Revocable POD Trust account under the Uninsured Amount field in the Account File.

Record an uninsured balance of $0 for Marsha McDonald’s Formal Revocable Trust account under the Uninsured Amount field in the Account File.



Marsha McDonald Formal Revocable Trust $0


The insured amount of $325,000 for Marsha McDonald’s Revocable POD Trust account is the difference between $875,000 and $550,000.

Record an insured balance of $925,000 for Marsha McDonald’s Formal Revocable Trust account under the Insured Amount field in the Account File.



Marsha McDonald Formal Revocable Trust $925,000



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Flag Marsha McDonald’s Revocable POD Trust account and her Formal Revocable Trust account as complete as the steps above are completed.

C.3.3.3 Outcome

No additional entry in the Customer File, Marsha McDonald has already been accounted for during the processing of the POD Trust account.

One additional entry in the Account File for Marsha McDonald’s Formal Revocable Trust account.

Update the entry previously entered for Marsha McDonald’s Revocable POD Trust account from scenario C.3.2 to reflect the change in insurance determination due to the identification of her Formal Revocable Trust account.

Two additional entries in the Account Participant File representing the Jones Foundation and Andrew McDonald as beneficiaries of Marsha McDonald Formal Revocable Trust account.

No entry in the Pending File as information is available to complete the insurance determination for both accounts.

C.3.4 Scenario 4

C.3.4.1 Background

Mark Carter has a living trust at a CI that grants his wife, Ruth Carter, a life estate interest. Upon Ruth Carter’s death, the couple’s five children are designated as remainder beneficiaries to equally share the total balance of the trust. The account has a total balance of $2,000,000. Assume this account is Mark Carter’s only account at the CI and that the account total balance includes an accrued interest of $15,000.

Beneficiary

Ruth Carter (Life Estate Beneficiary)

Virginia Carter

Matt Carter

Denise Carter

Bernard Carter

Terri Carter


1) Identify the account owners and unique eligible primary beneficiaries.

Mark Carter is the account owner.

Ruth Carter is an eligible life estate beneficiary.

Virginia Cater, Matt Carter, Denise Carter, Bernard Carter, and Terri Carter are eligible beneficiaries.


Mark Carter is the only account owner and has six eligible unique beneficiaries: Ruth Carter (life estate beneficiary), Virginia Cater, Matt Carter, Denise Carter, Bernard Carter, and Terri Carter.


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Based on the beneficiary allocation information presented in the trust documentation, Ruth Carter is a life estate beneficiary and the remaining account interest is to be divided equally across the five remaining eligible unique primary beneficiaries.

For purposes of calculating deposit insurance coverage, the life estate beneficiary is insured or valued at $250,000.

The beneficiary allocation is as follows:


Ruth Carter (Life Estate Beneficiary) $250,000

Virginia Carter $350,000

Matt Carter $350,000

Denise Carter $350,000

Bernard Carter $350,000

Terri Carter $350,000

Total $2,000,000


The aggregate total balance and accrued interest is $2,000,000 for all accounts in the REV right and capacity owned by Mark Carter.

This is the sum of eligible beneficiary allocations determined in step 3.


Not applicable, Mark Carter has six eligible beneficiaries with unequal interests. This can be seen in the beneficiary allocations determined in step 3.


Not applicable.


Not applicable.


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Not applicable.


Ruth Carter’s interest is insured up to $250,000.


Five out of the six beneficiaries have a beneficial interest that exceeds SMDIA.

Each of the six beneficiaries (including the life estate beneficiary) is insured up to $250,000 with a total insured amount of $1,500,000 (= 6 * $250,000).

The total insured amount is therefore $1,500,000, the greater of the sum of all beneficiaries’ insured amounts ($1,500,000) or $1,250,000.

b) If the total amount of the owner’s funds exceeds the insured amount determined based on the above, the excess is the uninsured amount for the owner.

The total amount $2,000,000 exceeds the insured amount of $1,500,000 by $500,000 and the excess of $500,000 is uninsured.


Ruth Carter (Life Estate Beneficiary) $250,000 $250,000 $0

Virginia Carter $350,000 $250,000 $100,000

Matt Carter $350,000 $250,000 $100,000

Denise Carter $350,000 $250,000 $100,000

Bernard Carter $350,000 $250,000 $100,000

Terri Carter $350,000 $250,000 $100,000

Total $2,000,000 $1,500,000 $500,000

Note: the above table is presented for illustration purposes only. In this case, such a table does not need to be created for purpose of insurance determination as the uninsured amount can be determined by a simple comparison of the total balance ($2,000,000) and the insured amount ($1,500,000).


Not applicable as Mark Carter does not have funds in a right and capacity other than REV.


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Applicable as Mark Carter has an uninsured amount of $500,000 in the REV right and capacity.


$15,000 of the total uninsured funds of $500,000 applies to the accrued interest first.


There is an uninsured amount of $485,000 remaining after step a. As this account is the only account Mark Carter has at the CI, apply the remaining $485,000 against the outstanding balance of this account.


Not applicable.


Not applicable.

9) Based on the above determination, determine record the respective uninsured amount of the owner to each associated account.

Record an uninsured balance of $500,000 for this account under the Uninsured Amount field in the Account File.


Mark Carter Formal Revocable Trust $500,000

10) The insured amount of the owner for each associated account is the difference between the owner’s interests in that

account and the uninsured amount determined based on the steps above.

Record an insured balance of $1,500,000 for this account under the Insured Amount field in the Account File.


Mark Carter Formal Revocable Trust $1,500,000


Flag this account as complete once the steps above are completed.

C.3.4.3 Outcome

One (1) entry in the Customer File representing Mark Carter.

One (1) entry in the Account File representing Mark Carter’s Formal Revocable Trust Account.

Six (6) entries in the Account Participant File representing each of the six eligible unique beneficiaries of Mark Carter’s Formal Revocable Trust.

No entry in the Pending File as complete information is available for purposes of the insurance determination.


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C.4 Irrevocable Trust Accounts

C.4.1 Scenario 1

C.4.1.1 Background

John Tango is the owner of an irrevocable charitable remainder trust account with a total balance of $750,000 invested in CD at a CI. Per the trust documentation, John may recover the total funds in this irrevocable trust account under certain prescribed circumstances. Upon John’s death, the account total balance will be distributed equally across three charities: The Tango Foundation, The Smith Foundation, and the Jones Foundation.

Beneficiaries with Equal Distribution

The Tango Foundation



In addition, John Tango has no other accounts at this CI. Assume for simplicity the amount above represents the outstanding total balance of the account (i.e., no accrued interest).



John Tango is the only grantor of the irrevocable trust account.

The Tango Foundation, the Smith Foundation, and the Jones Foundation are eligible beneficiaries.


Not applicable.

As John Tango retains the right to recover the funds in this irrevocable trust account under certain prescribed circumstances, the entire deposit of $750,000 is considered a “retained interest” of the grantor for deposit insurance purpose.

As a result, the account does not provide non-contingent interest to the three named beneficiaries for purposes of insurance determination.


Based on the terms of the trust documentation, the entire account total balance represents John Tango’s retained interest:

Allocation

Retained Interest $750,000


Not applicable.


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Not applicable.


Not applicable.


Not Applicable. None of the three named beneficiaries is a contingent beneficiary. In addition, as John Tango retains the right to recover the funds in this irrevocable trust account under certain prescribed circumstances, the entire deposit of $750,000 is considered a “retained interest” of the grantor for deposit insurance purposes. As a result, the account does not provide contingent interests to the three named beneficiaries for purposes of insurance determination.


Not applicable.


Not applicable.

6) The sum of the uninsured amounts from the non-contingent trust interests and contingent interests of the grantor is the total uninsured amount of the grantor in the IRR right and capacity at the CI.

Not applicable.


Since John Tango has no single account at the CI, his total interest in the single account right and capacity is equal to $750,000.


Not applicable. John Tango’s total funds in the single account right and capacity does exceed SMDIA.


John Tango’s total funds in the single account right and capacity does exceed SMDIA.

John Tango’s total balance of $750,000 is insured for $250,000, and the excess of $500,000 is uninsured.


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8) If there are uninsured funds for a grantor in the irrevocable trust account right and capacity, then for each irrevocable trust account associated with the grantor.

Not Applicable as John Tango does not have uninsured funds in the IRR right and capacity.


Not applicable.


Not applicable.


Not applicable.


Not applicable.


Not applicable as no fund in the irrevocable trust account is in the IRR right and capacity, the uninsured amount is zero (so is the total balance).

Account Right and Capacity Uninsured Amount

John Tango Charitable Remainder Trust IRR $0

9) If there are uninsured funds for a grantor in the single account right and capacity, then for each account the grantor has at the CI in the SGL right and capacity, perform step 8 as described above to determine the uninsured amount for each account the grantor has under the SGL right and capacity.

As John Tango does not have any other single accounts at the CI, the total uninsured amount of $500,000 is allocated to the irrevocable trust account.

Record an uninsured balance of $500,000 in the Account File under the Uninsured Amount field associated with the John Tango Charitable Remainder Trust account (Right and Capacity = SGL).


John Tango Charitable Remainder Trust SGL $500,000

10) For each grantor and for each right and capacity (IRR or SGL), the insured amount for each individual account is the difference between the funds of the account allocated to that right and capacity and the corresponding uninsured amount.

For the IRR right and capacity (Right and Capacity = IRR), record account balances of zero (DP_Allocated_Amt = DP_Acc_Int = DP_Total_PI=0) and insured and uninsured amount of zero for this irrevocable trust account.


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For the SGL right and capacity (Right and Capacity = SGL), record total balance of $750,000 (DP_Allocated_Amt = $750,000, DP_Acc_Int = $0, DP_Total_PI = $750,000), and insured balances in the Account File under the Insured Amount field of $250,000 for this irrevocable trust account.


John Tango Charitable Remainder Trust IRR $0 $0

John Tango Charitable Remainder Trust SGL $750,000 $250,000


Flag John Tango’s irrevocable trust account as complete as the steps above are completed.

C.4.1.3 Outcome

One entry in the Customer File representing John Tango.

Two entries in the Account File.

John Tango’s ownership interest in the IRR right and capacity from the irrevocable trust account.

John Tango’s ownership interest in the SGL right and capacity from the irrevocable trust account (the retained interest).

No entry in the Account Participant File as the designated beneficiaries are not factored into the insurance determination.


C.4.2 Scenario 2

C.4.2.1 Background

Lee Green is the owner of an irrevocable trust account with a total balance of $650,000 at a CI. Assume the trust documentation does not provide any right to the trustee or Lee Green to return any funds in the account to Lee Green under any circumstance. Per the trust documentation, the trust funds are allocated as follows:


Billy Green $100,000

Jane Green $250,000

Billy Green – Contingent upon completing college $150,000

Rachel Green – Contingent upon completing college $100,000

Rick Green – Contingent upon completing dental school $50,000

Total $650,000

In addition, Lee Green has no other accounts at this CI. Assume for simplicity the account is invested in non-interest bearing DDA and the amount above represents the outstanding total balance of the account (i.e., no accrued interest)




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Lee Green is the only grantor of the irrevocable trust account.

Billy Green, Jane Green, Rachel Green, and Rick Green are eligible beneficiaries.


Based on the beneficiary allocation information presented in the trust documentation, the non-contingent and contingent trust interests are as follows:

Non-Contingent Interest



Jane Green $250,000

Total $350,000

Contingent Interest



Rachel Green $100,000

Rick Green $50,000

Total $300,000


Not Applicable as the trust documentation does not provide any right to the trustee or Lee Green to return any

funds in the account to Lee Green under any circumstances.


Lee Green’s non-contingent interest totals $350,000 across the two non-contingent beneficiaries Billy Green and Jane Green. See table in step 2.


The total amount of non-contingent interest balance of $350,000 does not exceed $250,000 multiplied by two ( $250,000 * 2 = $500,000).

As a result, the total non-contingent interest balance of $350,000 is fully insured.


Not applicable.


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Lee Green’s contingent interest totals $300,000 across the three contingent beneficiaries Billy Green, Rachel Green and Jane Green. See the table in Step 2.


Not applicable.


Lee Green’s aggregate contingent interest of $300,000 exceeds insurance coverage of $250,000.

The excess of $50,000 is uninsured.

6) The sum of the uninsured amounts from the non-contingent trust interests and contingent interests of the grantor is the total uninsured amount of the grantor in the irrevocable trust account right and capacity at the CI.

Based on the determinations from step 4 and step 5 above, the uninsured amounts of non-contingent and contingent interests of Lee Green are as follows:

Total Balance Uninsured Amount

Non-Contingent Interest $350,000 $0

Contingent Interest $300,000 $50,000

Total $650,000 $50,000


Not applicable.


Not applicable.


Not applicable.


Applicable as the total uninsured amount is $50,000 based on determination from Step 6.


Not applicable as there is no accrued interest in this irrevocable trust account.


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As this irrevocable trust account is the only IRR account Lee Green holds at the CI, the total uninsured amount of $50,000 is allocated to this account.


Not applicable.


Not applicable.


Record the uninsured balance of $50,000 in the Account File under the Uninsured Amount field associated with the Lee Green’s irrevocable trust account.


Lee Green’s Irrevocable Trust $50,000

9) If there are uninsured funds for a grantor in the single account right and capacity, then for each account the grantor has at the CI in the SGL right and capacity, perform Step 8 as described above to determine the uninsured amount for each account the grantor has under the SGL right and capacity.

Not applicable.

10) For each grantor and for each right and capacity (IRR or SGL), the insured amount for each individual account is the difference between the funds of the account allocated to that right and capacity and the corresponding uninsured amount.

Not applicable for the SGL right and capacity as Lee Green does not have any retained interest in this account that can be attributed to the SGL right and capacity.

For the IRR right and capacity, record the insured amount of $600,000 (= $650,000 - $50,000) in the Account File under the Insured Amount field for Lee Green’s irrevocable trust account.

Account Right and Capacity Insured Amount

Lee Green Irrevocable Trust Account IRR $600,000


Flag this irrevocable trust account as complete as the steps above are completed.

C.4.2.3 Outcome

One entry in the Customer File representing Lee Green

One entry in the Account File for the funds Lee Green holds in the IRR right and capacity.


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Four entries in the Account Participant File, one each for Billy Green, Jane Green, Rachel Green, and Rick Green.


C.4.3 Scenario 3

C.4.3.1 Background

Tom Bradshaw is the owner of an irrevocable trust account with a total balance of $1,100,000 invested in non-interest bearing DDA at a CI. Per the trust documentation, the trust funds are allocated as follows, with any remaining funds representing Tom Bradshaw’s retained interest in the account ($200,000). Assume Tom Bradshaw does not have any other account at the CI.


Charles Bradshaw $200,000

William Bradshaw $200,000

Evan Bradshaw $50,000

Mary Bradshaw $50,000

Evan Bradshaw – Contingent upon completing college $200,000

Mary Bradshaw – Contingent upon completing college $200,000

Total $900,000

Assume for simplicity, the amount above represents the outstanding total balance of the account (i.e., no accrued interest).



Tom Bradshaw is the only grantor of this irrevocable trust account.

Charles Bradshaw, William Bradshaw, Evan Bradshaw, and Mary Bradshaw are eligible beneficiaries.


Based on the beneficiary allocation information presented in the trust documentation, the non-contingent and contingent trust interests are as follows:

Non-Contingent Interest


Charles Bradshaw $200,000

William Bradshaw $200,000



Total $500,000


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Contingent Interest




Total $400,000


Based on the trust documentation, funds not allocated to the beneficiaries represent retained interest of the grantor:

Interest Type Allocation

Retained Interest $200,000


Tom Bradshaw’s non-contingent interests total $500,000 across the four non-contingent beneficiaries. See table in step 2.


The total non-contingent interest balance of $500,000 does not exceed $250,000 multiplied by four ($250,000 x 4 = $1,000,000).

As a result, the total non-contingent interest balance of $500,000 is fully insured.


Not applicable.


Given Tom Bradshaw does not have any other account at the CI, Tom Bradshaw’s contingent interests for this trust account totals $400,000 across the two contingent beneficiaries. See the table in Step 2.


Not applicable.


Tom Bradshaw’s aggregate contingent interests of $400,000 exceeds insurance coverage of $250,000.


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The excess of $150,000 is uninsured.

6) The sum of the uninsured amounts from the non-contingent trust interests and contingent interests of the grantor is the total uninsured amount of the grantor in the irrevocable trust account right and capacity at the CI.

Based on determinations from step 4 and step 5, the total uninsured amounts of Tom Bradshaw’s non-contingent and contingent interests are as follows:

Interest Type Total Balance Uninsured Amount

Non-Contingent Interest $500,000 $0

Contingent Interest $400,000 $150,000

Total $900,000 $150,000

7) Aggregate each grantor’s retained interests (if any) with the grantor’s other single account interests (if any) at the CI. If

this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Since Tom Bradshaw has no other single account at the CI, his total interest in the single account right and capacity is equal to $200,000 (the retained interest).


Tom Bradshaw’s total funds in the single account right and capacity do not exceed SMDIA, his retained interest of $200,000 is fully insured.


Not applicable.


Applicable as, based on step 6 above, the uninsured amount of Tom Bradshaw in the IRR right and capacity is $150,000.


Not applicable as there is no accrued interest in this account.


As this irrevocable trust account is the only IRR account Tom Bradshaw has at the CI, the total uninsured amount of $150,000 is allocated to this account.

c) If post step b, there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance.

Not applicable.


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Not applicable.


Record an uninsured balance of $150,000 in the Account File under the Uninsured Amount field for Tom Bradshaw’s irrevocable trust account.


Tom Bradshaw Irrevocable Trust IRR $150,000

9) If there are uninsured funds for a grantor in the single account right and capacity, then for each account the grantor has at the CI in the SGL right and capacity, perform Step 8 as described above to determine the uninsured amount for each account the grantor has under the SGL right and capacity.

Not Applicable. Tom Bradshaw’s funds of $200,000 in the single account right and capacity are fully insured.


Tom Bradshaw Irrevocable Trust SGL $0

10) For each grantor and for each right and capacity (IRR or SGL), the insured amount for each individual account is the difference between funds of the account allocated to that right and capacity and the corresponding uninsured amount.

For the IRR right and capacity (Right and Capacity = IRR), the insured amount of $750,000 is the difference between the total balance of $900,000 and the uninsured amount of $150,000.

Record in the Account File under the Insured Amount field of $750,000 for his funds in this irrevocable trust account allocated to the IRR right and capacity.

For the SGL right and capacity (Right and Capacity = SGL), the insured amount of $200,000 is the difference between the total balance of $200,000 and the uninsured amount of $0.

Record in the Account File under the Insured Amount field of $200,000 for his funds in this irrevocable trust account allocated to the SGL right and capacity.


Tom Bradshaw Irrevocable Trust Account IRR $900,000 $750,000

Tom Bradshaw Irrevocable Trust Account SGL $200,000 $200,000

Total $1,100,000 $950,000


Flag this irrevocable trust account as complete when the steps above are completed.

C.4.3.3 Outcome

One (1) entry in the Customer File representing Tom Bradshaw.


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Two (2) entries in the Account File:

Tom Bradshaw’s ownership interest in the IRR right and capacity from the irrevocable trust account.

Tom Bradshaw’s ownership interest in the SGL right and capacity (the retained interest) from the irrevocable trust account.

Four (4) entries in the Account Participant File, one each for Charles Bradshaw, William Bradshaw, Evan Bradshaw, and Mary Bradshaw.



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C.5 Certain Retirement Accounts

C.5.1 Scenario 1

C.5.1.1 Background

Barbara Moore has two IRA CDs at the same CI. She has listed two IRA beneficiaries on each CD.

Account Title Deposit Type Total Balance

Barbara Moore's Roth IRA(Beneficiaries: Lisa Moore & Roger Moore) CD $100,000

Barbara Moore's Traditional IRA (Beneficiaries: Lisa Moore & Roger Moore) CD $195,000

Total $295,000

Assume for simplicity all the amounts above represent the outstanding total balance of each account (i.e., no accrued interest).


1) Identify all certain retirement accounts by the account owner.

Barbara Moore is the account owner for both accounts and these two accounts are all CRA accounts Barbara Moore has at the CI.

2) Aggregate total account balance and accrued interest by each account owner for those accounts held in the CRA right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balance and accrued interest for Barbara Moore across these two accounts is $295,000.

3) For the aggregated account balance and accrued interest for each account owner,

a) If the total balance and accrued interest of the account owner does not exceed SMDIA, then the funds are fully insured.

Not applicable, total balance exceeds SMDIA.

b) If the total balance and accrued interest allocated to account owner do exceed SMDIA, then funds in excess of SMDIA are not insured.

Applicable as the total balance of $295,000 exceeds SMDIA by $45,000 and the excess is the uninsured amount.



Not applicable.

b) If there is an uninsured amount remaining after step a, determine the owner’s CRA account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Both accounts are held in the same product category (CD), proceed to step c.


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Apply the entire uninsured funds of $45,000 to the Traditional IRA account as it has a higher total balance than the Roth IRA account.


Not applicable.

5) Based on the above determination, record the uninsured amount to each account associated with the account owner.

Record uninsured balance of $45,000 in the Account File under the Uninsured Amount field for the Traditional IRA account.


Barbara Moore's Roth IRA (Beneficiaries: Lisa Moore & Roger Moore) $0

Barbara Moore's Traditional IRA (Beneficiaries: Lisa Moore & Roger Moore) $45,000

Total $45,000


Record insured balances in the Account File under the Insured Amount field of $100,000 and $150,000 for the Roth IRA and Traditional IRA accounts, respectively.


Barbara Moore's Roth IRA (Beneficiaries: Lisa Moore & Roger Moore) $100,000

Barbara Moore's Traditional IRA (Beneficiaries: Lisa Moore & Roger Moore) $150,000

Total $250,000

7) Flag accounts that have been processed as an insurance determination completed.

Flag both accounts as complete after the steps above are completed.

C.5.1.3 Outcome

One (1) entry in the Customer File for Barbara Moore.

Two (2) entries in the Account File: one for Roth IRA and one for Traditional IRA.

No entry in the Account Participant File as listed beneficiaries on the CRA accounts do not affect deposit insurance calculation.



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C.6 Employee Benefit Plan Accounts

C.6.1 Scenario 1

C.6.1.1 Background

Medical Services of Mainville, a small doctor’s office, has four employees, each of whom participates in the employee benefit plan. These employees do not participate in any other employee benefit plan sponsored by the same employer. The plan administrator invested $700,000 in CDs at the CI. The employee benefit plan defines the interest of each plan participant. Under the terms of the plan documents, the interests of the participants are non-contingent. The respective interests of the participants are set forth below:

Plan Participants Share of Plan Deposit Amount

Dr. Moore 40% $280,000

Dr. Wilson 35% $245,000

Nurse Smith 15% $105,000

Mrs. Taylor 10% $70,000

Plan Total 100% $700,000

Similarly, Dr. Moore also participates in an employee benefit plan for his business with Dr. Stevens, Moore Stevens Med. The plan administrator invested $500,000 in CDs at the same CI. Under the terms of the plan documents, the interests of the participants are non-contingent and 20% of the plan share is contributed and set aside by Moore Stevens Med as overfunding to cover operational and administrative costs. The respective interests of the plan are set forth below:

Plan Participants Share of Plan Deposit Amount

Dr. Moore 40% $200,000

Dr. Stevens 40% $200,000

Overfunding 20% $100,000

Plan Total 100% $500,000

Neither employer has any other account with the same CI and assume for simplicity all the amounts above represent the total balance (i.e., no accrued interest).


1) Identify all employee benefit plan accounts by unique account employer and unique plan participants.

Account Participant Medical Services of Mainville Moore Stevens Med

Dr. Moore

Dr. Wilson

Nurse Smith

Mrs. Taylor

Dr. Stevens

2) Aggregate total account balance and accrued interest by each unique plan participant for all “non-contingent interests.” If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified


Page | 109

account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Based on the plan participant information, each plan participant’s “non-contingent” interest is as follows:

Account Participant Medical Services of Mainville Moore Stevens Med Total Balance

Dr. Moore $280,000 $200,000 $480,000

Dr. Wilson $245,000 $0 $245,000

Nurse Smith $105,000 $0 $105,000

Mrs. Taylor $70,000 $0 $70,000

Dr. Stevens $0 $200,000 $200,000

Total $700,000 $400,000 $1,100,000

3) Aggregate total account balance and accrued interest by each unique plan participant for all “contingent interests.” If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Not applicable as there is no contingent interest.

4) Aggregate total account balance and accrued interest by each unique employer for all overfunding. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Based on the information above, each employer’s overfunding is as follows:

Employer Overfunding

Medical Services of Mainville $0

Moore Stevens Med $100,000



Not applicable for Dr. Moore as his total balance exceeds SMDIA.

Applicable for all other plan participants and their funds in the EBP right and capacity are fully insured.

Applicable for the overfunding amount and the total amount of $100,000 is fully insured in the BUS right and capacity.

Plan Participant Total Allocation Insured Amount Uninsured Amount

Dr. Moore – Non-Contingent $480,000 $250,000 $230,000

Dr. Wilson – Non-Contingent $245,000 $245,000 $0

Nurse Smith – Non-Contingent $105,000 $105,000 $0

Mrs. Taylor – Non-Contingent $70,000 $70,000 $0

Dr. Stevens – Non-Contingent $200,000 $200,000 $0

Overfunding $100,000 $100,000 $0



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Applicable as for Dr. Moore as there is an uninsured amount of $230,000 for Dr. Moore. See the table in step 5a.

6) If there are uninsured funds for a plan participant in the EBP right and capacity, then:

Applicable for Dr. Moore’s deposit interests in the EBP right and capacity.


Not applicable.

b) If there is an uninsured amount remaining after step a, apply the uninsured amount for each plan participant with an uninsured amount as follows:

i) Determine the allocation ratio for each plan participant with remaining uninsured funds by dividing the plan participant’s uninsured amount by the plan participant’s aggregate total balance calculated in steps 2 and 3.

The allocation ratio for Dr. Moore is calculated as follows:

Plan Participant Uninsured Amount Allocation Allocation Ratio27

Dr. Moore $230,000 $480,000 47.92%=$230,000/$480,000

ii) Allocate the remaining uninsured amount for the plan participant based on the allocation ratio calculated in step i.

Allocation of Dr. Moore’s uninsured amount of $230,000 across these two accounts is as follows:

Employer Dr. Moore’s Interest (A)

Dr. Moore’s Allocation Ratio (B)

Dr. Moore Allocated Uninsured Amount (A*B)

Medical Services of Mainville $280,000 47.92% $134,167

Moore Stevens Med $200,000 47.92% $95,833

Total $480,000 $230,000

iii) Determine the total uninsured amount for each account based on the allocated uninsured amount of all plan participants with uninsured funds.

As Dr. Moore is the only plan participant with uninsured funds, his allocated uninsured amount for each account represents the total uninsured amount for each of those accounts.

7) If there are uninsured funds for the employer in the BUS right and capacity, then:

Not applicable as there are no uninsured funds in the BUS right and capacity.


Not applicable.

b) If there is an uninsured amount remaining after step a, determine the employer’s BUS account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Not applicable.

27

For the purposes of this document the percentage has been rounded to two decimal places.


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Not applicable.


Not applicable.

8) Based on the above determination, determine and record the uninsured amounts to the accounts in each right and capacity (EBP or BUS).

For the funds in the BUS right and capacity, there is no uninsured amount.

For the funds in the EBP right and capacity, record the following uninsured amounts for these two accounts in the Account File under the Uninsured Amount field:

Employer Right and Capacity Uninsured Amount

Medical Services of Mainville EBP $134,167

Moore Stevens Med BUS $0

Moore Stevens Med EBP $95,833

Total $230,000

9) The insured amount for each individual account is the difference between funds allocated to each right and capacity (EBP or BUS) and the uninsured amount.

For deposits in the EBP right and capacity, record the following insured amounts for these two accounts in the Account File under the Insured Amount field:

Employer Right and Capacity Insured Amount

Medical Services of Mainville EBP $565,833

Moore Stevens Med EBP $304,167

For deposits in the BUS right and capacity, record the following insured amount for Moore Stevens Med.

Employer Right and Capacity Insured Amount

Moore Stevens Med BUS $100,000


Flag both accounts as complete as the steps above are completed.

C.6.1.3 Outcome

Two (2) entries in the Customer File, one for Medical Services of Mainville, Inc. and the other for Moore Stevens Med, Inc.

Three (3) entries in the Account File: one for each of the employee benefit plans for Medical Services of Mainville, Inc. and Moore Stevens Med, Inc. as well as one entry for the funds in the business account right and capacity representing overfunding contributed by Moore Stevens Med, Inc.


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The overfunding of $100,000 for Moore Stevens Med is fully insured as funds in the business account right and capacity for this employer.

Six (6) entries in the Account Participant File: one for each unique combination of employer and plan participant



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C.7 Business Accounts

C.7.1 Scenario 1

C.7.1.1 Background

XYZ Dredging, Inc., a corporation, holds two accounts at a CI, a non-interest bearing DDA account with a total balance of $200,000 and a non-interest bearing DDA account with a total balance of $40,000. QRS Dynamite, Inc., a wholly owned subsidiary of XYZ Dredging, Inc., also holds accounts at the same CI. QRS Dynamite, Inc. is a separately incorporated subsidiary from its parent company and engages in independent activity from XYZ Dredging Inc. QRS Dynamite, Inc. holds a $150,000 CD at the CI and the QRS Dynamite, Inc. also holds a non-interest bearing DDA account with a total balance of $120,000 for its Risk Division.

Account Owner Deposit Type Total Balance

XYZ Dredging, Inc. DDA $200,000


QRS Dynamite, Inc. CD $150,000

QRS Dynamite, Inc. – Risk Division DDA $120,000

Total

$510,000

Assume neither of the above two entities holds any other account at the CI. Assume the QRS Dynamite, Inc. CD total balance of $150,000 includes $5,000 in accrued interest.



For the two business accounts held by XYZ Dredging, Inc., the account owner is XYZ Dredging, Inc.

For the two business accounts held by QRS Dynamite, Inc., the account owner is QRS Dynamite, Inc.

Note although QRS Dynamite, Inc. is a subsidiary of XYZ Dredging, Inc., as it is separately incorporated and engages in independent activity, it is insured separately from its parent company.

As QRS Dynamite, Inc.’s Risk Division is not separately incorporated from QRS Dynamite, Inc., the account QRS Dynamite, Inc. holds for the Risk Division is not separately insured from the account the company holds for itself.

2) Aggregate total account balance and accrued interest of the corporation, partnership, or unincorporated association across all accounts the entity holds in the BUS right and capacity at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Aggregated total balance and accrued interest for each unique corporation are as follows:




Total $240,000


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QRS Dynamite, Inc. DDA $120,000

Total $270,000


Total balance of XYZ Dredging, Inc. does not exceed SMDIA and the total balance of $240,000 is fully insured.

Account Owner Total Balance Uninsured Amount

XYZ Dredging, Inc. $240,000 $0


Total balance of QRS Dynamite, Inc. does exceed SMDIA and the excess of $20,000 is the uninsured amount.

Account Owner Total Balance Uninsured Amount

QRS Dynamite, Inc. $270,000 $20,000


Not applicable for XYZ Dredging, Inc. as it does not have an uninsured amount.

Applicable for QRS Dynamite, Inc. as it does have an uninsured amount of $20,000.


$5,000 of the total uninsured funds of $20,000 applies to the accrued interest of the CD account for QRS Dynamite, Inc.


Apply the remaining uninsured amount of $15,000 of QRS Dynamite, Inc. to its CD account based on the liquidity priority order.

In total, the uninsured amount allocated to QRS Dynamite, Inc.’s CD account is $20,000.


Not applicable.


Not applicable.

4) Based on the above determination, determine and record the uninsured amounts to each business account the corporation, partnership, or unincorporated association has at the CI.


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Based on determinations from step 2 and step 3 above, record the uninsured balances in the Account File under the Uninsured Amount field as follows:

Account Owner Deposit Type Uninsured Amount

XYZ Dredging, Inc. DDA $0

XYZ Dredging, Inc. DDA $0


QRS Dynamite, Inc. DDA $0


For each account, the insured amount is equal to the difference between the total balance and the uninsured amount determined in step 4 above.

Record the insured balances in the Account File under the Uninsured Amount field as follows:

Account Owner Deposit Type Total Balance Insured Amount

XYZ Dredging, Inc. DDA $200,000 $200,000

XYZ Dredging, Inc. DDA $40,000 $40,000

QRS Dynamite, Inc. CD $150,000 $130,000

QRS Dynamite, Inc. DDA $120,000 $120,000


Flag all four accounts as complete after the steps above are completed.

C.7.1.3 Outcome

Two (2) entries in the Customer File, one for XYZ Dredging, Inc. and one for QRS Dynamite, Inc.

Four (4) entries in the Account File, one for each account.




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C.8 Government Accounts

C.8.1 Scenario 1

C.8.1.1 Background

Bernice Lewis and Andy Jackson are official custodians for the Municipality of Magenta. At a CI located within the same state as the Municipality of Magenta, both Bernice Lewis and Andy Jackson are listed as official custodians for a CD account with a total balance of $600,000 and an DDA with a total balance of $300,000. Barbara Lane is listed as the official custodian for a NOW account held at the same CI for the Municipality of Orange, located in a neighboring state, with a total balance of $260,000. The CI holds no pledged securities for either municipality.

Account Title Deposit

Type Location of

Deposits Total

Balance

Municipality of Magenta (Custodians: Bernice Lewis and Andy Jackson) CD In-State $600,000

Municipality of Magenta (Custodians: Bernice Lewis and Andy Jackson) DDA In-State $300,000

Municipality of Orange (Custodian: Barbara Lane) NOW Out-of-State $260,000

Total

$1,160,000

Assume for simplicity all the amounts above represent the outstanding total balance of each account (i.e., no accrued interest). Assume neither municipality holds any other account at the CI.


1) Identify all unique combinations of official custodians, public units, and government account Right and Capacity (GOV1, GOV2, and GOV3).

Based on the information provided, the unique combinations of official custodians, public units, and government account right and capacity (GOV1, GOV2, and GOV3) are as follows:

Public Unit Custodian(s) Deposit Type Right and Capacity

Municipality of Magenta Bernice Lewis & Andy Jackson CD GOV1

Municipality of Magenta Bernice Lewis & Andy Jackson DDA GOV2

Municipality of Orange Barbara Lane NOW GOV3

Note: For the municipalities, GOV1 is for time and savings account held at an in-state CI, GOV2 is for demand deposit account held at an in-state CI, and GOV3 is for deposit account held at an out-of-state CI (regardless of the product type).

2) Aggregate total account balance and accrued interest by each unique combination of official custodians, public units, and government account right and capacity (GOV1, GOV2, and GOV3). If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balance and accrued interest for each combination is as follows:

Public Unit Custodian(s) Right and Capacity Total Balance

Municipality of Magenta Bernice Lewis & Andy Jackson GOV1 $600,000


Municipality of Orange Barbara Lane GOV3 $260,000

3) For each of the aggregated amounts above:


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a) If the total balance and accrued interest does not exceed SMDIA times the number of official custodians, then the funds are fully insured.

For the GOV2 account, the total amount does not exceed SMDIA multiplied by 2 (= $500,000) and the total funds of $300,000 are fully insured.


For the GOV1 account, the total funds do exceed SMDIA multiplied by 2 (= $500,000) and the excess of $100,000 is the uninsured amount.

For the GOV3 account, the total funds do exceed SMDIA multiplied by 1 (= $250,000) and the excess of $10,000 is the uninsured amount.

Based on the above, the account insurance coverage for the three accounts is as follows:

Public Unit Custodian(s) Right and Capacity

Total Balance

Insured Amount

Uninsured Amount

Municipality of Magenta Bernice Lewis & Andy Jackson GOV1 $600,000 $500,000 $100,000

Municipality of Magenta Bernice Lewis & Andy Jackson GOV2 $300,000 $300,000 $0

Municipality of Orange Barbara Lane GOV3 $260,000 $250,000 $10,000


Applicable for GOV1 and GOV3 accounts.

Not applicable for the GOV2 account.

a) If the government entity has an outstanding security pledge with the CI, then place the account in the Pending File (see Section 5.4 of this document).

Not applicable.


i) Apply the uninsured amount to the accrued interests of all such accounts (if any).

Not applicable.

ii) If there is an uninsured amount remaining after step i, determine the government account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

As both the GOV1 and GOV3 accounts are the only accounts the municipalities hold in each right and capacity, the entire uninsured amount for each is applied to each of these two accounts.

Public Unit Custodian(s) Right and Capacity Uninsured Amount



iii) If after step ii, there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.

Not applicable.


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iv) If after step iii, there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

Not applicable.


Record uninsured balances in the Account File under the Uninsured Amount field as follows:

Public Unit Custodian(s) Right and Capacity Uninsured Amount


Municipality of Magenta Bernice Lewis & Andy Jackson GOV2 $0


6) The insured amount for each individual account is the difference between the funds held in each right and capacity (GOV1, GOV2, and GOV3) and the uninsured amount.

Record insured balances in the Account File under the Insured Amount field as follows:

Public Unit Custodian(s) Right and Capacity Insured Amount






C.8.1.3 Outcome

Two (2) entries in the Customer File: one for the Municipality of Magenta and one for the Municipality of Orange.

As the CI does not hold pledged securities for either municipality, set CS_Security_Pledge_Flag = N for both.

Three (3) entries in the Account File: one for each unique combination of official custodian, public unit, and government account right and capacity (GOV1, GOV2, and GOV3).

Five (5) entries in the Account Participant File as shown below: one for each unique combination of individual official custodian, public unit, and government account right and capacity.

Public Unit Custodian Right and Capacity

Municipality of Magenta Bernice Lewis GOV1

Municipality of Magenta Andy Jackson GOV1

Municipality of Magenta Bernice Lewis GOV2

Municipality of Magenta Andy Jackson GOV2

Municipality of Orange Barbara Lane GOV3



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C.9 Mortgage Servicing Accounts

C.9.1 Scenario 1

C.9.1.1 Background

The CI holds mortgage servicing accounts for two local mortgage servicers, Smithtown Mortgage Servicing and Newton Mortgage Servicing. Each mortgage servicer holds the comingled payments of principal and interest (“P&I”) made by mortgagors, including those of two local real estate developers, Ryan Andersen and Ann Wilson. Each mortgage servicing account also contains overfunding contributed by the mortgage servicer to cover operational and administrative costs. Neither mortgage servicing account contains taxes and insurance (“T&I”) contributed by the mortgagors. Both accounts are held in non-interest bearing DDAs. The interests in each mortgage servicing account are as follows:

Smithtown Mortgage Servicing

Mortgagor Total Balance

Ryan Andersen – Property A $150,000

Ryan Andersen – Property B $75,000

Ryan Andersen – Property C $50,000

Ann Wilson – Property A $10,000

Tony Harper $5,000

Overfunding $100,000

Total $390,000

Newton Mortgage Servicing

Mortgagor Total

Balance

Ryan Andersen – Property D $100,000

Ann Wilson – Property B $125,000

Ann Wilson – Property C $120,000

Jack Miller $2,000

Overfunding $175,000

Total $522,000

In addition, neither of these two mortgage servicers has any other accounts at this CI.


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1) Identify all unique combinations of mortgage servicer and mortgagor.

Unique combinations of mortgage servicer and mortgagor are as follows:

Unique Combinations of Mortgage Servicer and Mortgagor

Smithtown Mortgage Servicing Newton Mortgage Servicing

Ryan Andersen Ryan Andersen

Ann Wilson Ann Wilson

Tony Harper Jack Miller

In total, there are six unique combinations of mortgage servicer and mortgagor.

2) Aggregate total account balance and accrued interest associated with P&I payments by each unique combination of mortgage servicer and mortgagor for those accounts held in the MSA right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Aggregate total balance and accrued interest for each unique combination of mortgage servicer and mortgagor held under the MSA right and capacity is as follows:



Ryan Andersen $275,000

Ann Wilson $10,000

Tony Harper $5,000

Total $290,000



Ryan Andersen $100,000

Ann Wilson $245,000

Jack Miller $2,000

Total $347,000

3) Aggregate total account balance and accrued interest by each mortgage servicer for all overfunding (if any) and insure the total funds of each mortgage servicer under the Business Account right and capacity (together with the other funds each mortgage servicer has under the Business Account right and capacity at the same CI). If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).


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Total balance and accrued interest for each mortgage servicer held under the BUS right and capacity is as follows:

Mortgage Servicing Provider Overfunding Amount

Smithtown Mortgage Servicing $100,000

Newton Mortgage Servicing $175,000

Total $275,000

Each of the overfunding amounts for these two mortgage servicers is insured under the Business Account right and capacity (after aggregation of funds each of them may have in other Business Accounts at the same CI which is assumed to be zero in this scenario).

4) Aggregate the total T&I payments contributed by each mortgagor (if any) across the mortgage servicers and aggregate the total T&I funds of each mortgagor with the other funds each mortgagor has under the same right and capacity at the same CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Not applicable. Neither of these two mortgage servicing accounts has funds contributed by the mortgagors as T&I payments.



For the aggregated amount by mortgage servicer and mortgagor under the MSA right and capacity:

Not applicable for Ryan Andersen’s funds held with Smithtown Mortgage Servicing as his total fund exceeds SMDIA.

For all other unique combination of mortgage servicer and mortgagor, the total fund of each mortgagor does not exceed SMDIA and the fund is fully insured.


Mortgagor Total Balance Insured Amount Uninsured Amount

Ann Wilson $10,000 $10,000 $0

Tony Harper $5,000 $5,000 $0

Total $15,000 $15,000 $0



Ryan Andersen $100,000 $100,000 $0

Ann Wilson $245,000 $245,000 $0

Jack Miller $2,000 $2,000 $0

Total $347,000 $347,000 $0

For the aggregated amount by mortgage servicer under the BUS right and capacity.

The funds for each mortgage servicer does not exceed SIMDA and are therefore fully insured.


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Mortgage Servicing Provider Right and Capacity

Total Balance Insured Amount

Uninsured Amount

Smithtown Mortgage Servicing BUS $100,000 $100,000 $0

Newton Mortgage Servicing BUS $175,000 $175,000 $0

Total $275,000 $275,000 $0

For the aggregated amount of T&I payments by mortgagor under the SGL right and capacity: Not applicable.


For the aggregated amount by mortgage servicer and mortgagor under the MSA right and capacity:

Applicable for Ryan Andersen’s funds held with Smithtown Mortgage Servicing as his total funds exceed SMDIA.



Ryan Andersen $275,000 $250,000 $25,000

Total $275,000 $250,000 $25,000

Not applicable for all other unique combinations of mortgage servicer and mortgagor.

Not applicable for the aggregated amount by mortgage servicer under the BUS right and capacity.

Not applicable for the aggregated amount by mortgagor under the SGL right and capacity.

6) After going through steps 5a and 5b, determine the uninsured amounts for the unique combination of mortgagor and mortgage servicer under the MSA right and capacity, by mortgage servicer under the BUS right and capacity (if applicable), and by mortgagor under the respective ORC (if applicable).

By mortgagor and mortgage servicer under the MSA right and capacity:



Ryan Andersen $275,000 $250,000 $25,000

Ann Wilson $10,000 $10,000 $0

Tony Harper $5,000 $5,000 $0

Total $290,000 $265,000 $25,000



Ryan Andersen $100,000 $100,000 $0

Ann Wilson $245,000 $245,000 $0

Jack Miller $2,000 $2,000 $0

Total $347,000 $347,000 $0

By mortgage servicer under the BUS right and capacity.


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Mortgage Servicing Provider Right and Capacity Total Balance Insured Amount

Uninsured Amount

Smithtown Mortgage Servicing BUS $100,000 $100,000 $0

Newton Mortgage Servicing BUS $175,000 $175,000 $0

Total $275,000 $275,000 $0

By mortgagor under the SGL right and capacity: Not applicable.

7) For each mortgage servicer (or mortgagor), if there are uninsured funds under an ORC other than MSA, then perform the following steps for all accounts associated with the mortgage servicer (or the mortgagor) under each of such right and capacity:

Not applicable as there are no uninsured funds under BUS or SGL right and capacity for either of these two MSA accounts.

a) Apply the uninsured amount first to the accrued interests (if any) of all accounts.

Not applicable.

b) If there is an uninsured amount remaining after step a, determine the accounts that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Not applicable.


Not applicable.


Not applicable.

e) Based on the above determination, determine the uninsured amount to each mortgage servicing account under the corresponding right and capacity.

As there is no uninsured amount for either of these two mortgage servicing accounts under a right and capacity other than MSA, the uninsured amount allocated to either of these two accounts under those right and capacity categories is $0.

The uninsured funds under the BUS right and capacity are $0 for both accounts.

8) Determine the uninsured amount for each mortgage servicing account based on results from Step 7 and record the uninsured amount for that mortgage servicing account by right and capacity.

Record uninsured balance of $25,000 in the Account File under the Uninsured Amount field for Smithtown Mortgage Servicing account under the MSA right and capacity; $0 under the BUS right and capacity.


Smithtown Mortgage Servicing Account MSA $25,000

Smithtown Mortgage Servicing Account BUS $0


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The uninsured amount for Newton Mortgage Servicing account is zero (Uninsured Amount=0) under both the MSA and BUS right and capacity.


Newton Mortgage Servicing Account MSA $0

Newton Mortgage Servicing Account BUS $0

9) The insured amount for each individual account is the difference between the sum of current balance and accrued

interest and the uninsured amount.

Record insured balances in the Account File under the Insured Amount fields as follows:

Account Owner Right and Capacity Insured Amount

Smithtown Mortgage Servicing MSA $265,000

Smithtown Mortgage Servicing BUS $100,000

Total $365,000


Newton Mortgage Servicing MSA $347,000

Newton Mortgage Servicing BUS $175,000

Total $522,000


Flag these two accounts as complete after the steps above are completed.

C.9.1.3 Outcome

Two (2) entries in the Customer File, one for Smithtown Mortgage Servicing and one for Newton Mortgage Servicing.

Four (4) entries in the Account File:

One (1) entry for the funds from Smithtown Mortgage Servicing account in the MSA right and capacity.

One (1) entry for the funds associated with Smithtown Mortgage Servicing’s overfunding in the BUS right and capacity.

One (1) entry for the funds from Newton Mortgage Servicing account in the MSA right and capacity.

One (1) entry for the funds associated with Newton Mortgage Servicing’s overfunding in the BUS right and capacity.

Six (6) entries in the Account Participant File: one for each unique combination of mortgage servicer and mortgagor.



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C.10 Accounts held by a Depository Institution (DI) as the Trustee of an Irrevocable Trust

C.10.1 Scenario 1

C.10.1.1 Background

Ocean Bank is the trustee of an irrevocable trust and it holds the trust funds in a non-interest bearing DDA at a CI with a total balance of $500,000. The grantor of the irrevocable trust, Gene Holiday, is deceased, as of one year ago. The trust account has two beneficiaries, Susan Holliday and Roger Holliday. Per the trust documentation, the trust funds are allocated as follows:


Susan Holliday $300,000

Roger Holliday $200,000

Total $500,000

Assume neither Susan Holiday nor Roger Holiday holds any other DIT account or is the beneficiary of any other DIT account at the same CI.


1) Identify all trust fund owner(s) or beneficiaries.

Ocean Bank is the trustee and Gene Holiday is the deceased grantor of the irrevocable trust.

Susan Holliday and Roger Holliday are two eligible beneficiaries (or trust fund owners).

2) Aggregate the total account balance and accrued interest of each trust fund owner or beneficiary for all accounts the trust owner or beneficiary holds with the same depository institution and for the same trust under the DIT right and capacity at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balances and accrued interests for the two trust fund owners are as follows:


Susan Holliday $300,000

Roger Holliday $200,000

Total $500,000

3) For the aggregated account balance and accrued interest of each trust fund owner or beneficiary:


The aggregate balance and accrued interest for Roger Holliday does not exceed SMDIA and his total funds of $200,000 are fully insured.

Beneficiary Beneficiary Allocation Uninsured Amount

Roger Holliday $200,000 $0

b) If the total balance and accrued interest exceeds SMDIA, then funds in excess of SMDIA are not insured


Page | 126

The aggregate balance and accrued interest for Susan Holliday exceeds SMDIA and the excess of $50,000 is uninsured.


Susan Holliday $300,000 $50,000

4) If there are uninsured funds for the trust fund owner or beneficiary, then:

Not applicable for Roger Holiday as he does not have uninsured funds.

Applicable for Susan Holiday as she has an uninsured amount of $50,000.


Not applicable for Susan Holiday as the DIT account does not carry any accrued interest.

b) If there is an uninsured amount remaining after step a, determine the DIT account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Apply Susan Holiday’s entire uninsured amount of $50,000 to this DIT account as it is the only DIT account she holds at the CI.


Not applicable.


Not applicable.

5) Based on the above determination, determine and record the respective uninsured amount of each DIT account the trust fund owner or beneficiary has at the CI.

Record an uninsured balance of $50,000 for Susan Holiday under the Uninsured Amount field in the Account File.

Record an uninsured amount of $0 for Roger Holiday under the Uninsured Amount field in the Account File.



Roger Holliday $200,000 $0

Total $500,000 $50,000

6) Determine the insured amount for each DIT account of the trust account owner or beneficiary as the difference between his or her funds in the account and the uninsured amount.

Record the insured amount of $250,000 for Susan Holiday under the Insured Amount field in the Account File.

Record the insured amount of $200,000 for Roger Holiday under the Insured Amount field in the Account File.


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Beneficiary Beneficiary Allocation Insured Amount


Roger Holliday $200,000 $200,000

Total $500,000 $450,000

7) Flag the accounts that have been processed as an insurance determination is completed.

Flag this account as complete as the steps above are completed.

C.10.1.3 Outcome

One (1) entry in the Customer File representing Ocean Bank (the trustee).

One (1) entry in the Account File representing this DIT account held by Ocean Bank.

Two (2) entries in the Account Participant File: one for Susan Holiday and one for Roger Holiday.



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C.11 Annuity Contract Accounts

C.11.1 Scenario 1

C.11.1.1 Background

ABC Insurance Company holds annuity contract account for two annuitants, Hope Rollins and Janet Collins at a CI. The account is held in non-interest bearing DDA and the account balance is allocated to the two annuitants as follows:

Annuitant Total Balance

Hope Rollins $200,000

Janet Collins $250,000

Total $450,000

Assume ABC Insurance Company does not hold any other ANC account at the CI and neither of annuitants has any other ANC account at the CI. In addition, assume, according to the applicable state law, the funds in this account are owned by ABC Insurance Company (not by the annuitants).


1) Identify all unique combinations of insurance company/corporation and annuitant.

ABC Insurance Company is the insurance company and Hope Rollins and Janet Collins are the annuitants.

Insurance Company Annuitant

ABC Insurance Company Hope Rollins

ABC Insurance Company Janet Collins

2) Aggregate total account balance and accrued interest for each unique combination of insurance company/corporation and annuitant for all accounts held in the ANC right and capacity at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balances and accrued interest for the combination of ABC Insurance Company and each of these two annuitants are as follows:

Insurance Company Annuitant Total Balance

ABC Insurance Company Hope Rollins $200,000

ABC Insurance Company Janet Collins $250,000

Total

$450,000

3) Aggregate total account balance and accrued interest by insurance company or corporation for all overfunding (if any) and insure it together with the funds each insurance company or corporation has in all other business accounts at the CI under the BUS right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Not Applicable as there is no overfunding in this account.

4) For each of the aforementioned aggregations (under ANC or BUS right and capacity):



Page | 129

The total balances and accrued interests for Hope Rollins and Janet Collins do not exceed SMDIA. Their respective funds in the ANC right and capacity are fully insured.


Not applicable.

c) After going through steps 4a and 4b, determine the uninsured amounts for the unique combination of insurance company/corporation and annuitant under the ANC right and capacity and by insurance company/corporation under the BUS right and capacity (if applicable).

For the ANC right and capacity, the uninsured amount for both annuitants is zero.

Insurance Company Annuitant Total Balance Uninsured Amount

ABC Insurance Company Hope Rollins $200,000 $0

ABC Insurance Company Janet Collins $250,000 $0

Total

$450,000 $0

For the BUS right and capacity, not applicable as there are no funds in this category.

5) For each combination of annuitant and insurance company, if there are uninsured funds under the ANC right and capacity, then perform the following steps for all ANC accounts the annuitant has with the insurance company at the CI:

Not applicable as there are no uninsured funds for either combination of insurance company and annuitant.


Not applicable.

b) If there is an uninsured amount remaining after step a, determine the accounts that will be uninsured by following the liquidity priority order (see Section 4.2.16 of this document).

Not applicable.


Not applicable.


Not applicable.

e) Based on the above determination, determine the uninsured amount to each ANC account the annuitant has with the insurance company under the ANC right and capacity.

The uninsured amount for the ANC account each annuitant has with ABC Insurance Company is $0 and the uninsured amount is applied to this account for both annuitants as it is the only ANC account they hold at the CI.


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Insurance Company Annuitant Total Balance Uninsured Amount

ABC Insurance Company Hope Rollins $200,000 $0

ABC Insurance Company Janet Collins $250,000 $0

Total

$450,000 $0

6) For each insurance company or corporation, if there are uninsured funds under the BUS right and capacity, then perform the following steps for all business accounts the insurance company or corporation has at the CI:

Not applicable.


Not applicable.

b) If there is an uninsured amount remaining after step a, determine the accounts that will be uninsured by following the liquidity priority order (see Section 4.2.16 of this document).

Not applicable.


Not applicable.


Not applicable.

e) Based on the above determination, determine the uninsured amount to each account the insurance company or corporation has under the BUS right and capacity.

Not applicable.

7) Determine the uninsured amount for each annuity contract account based on results from step 5 and step 6 and record the uninsured amount for that annuity contract account by right and capacity (ANC and BUS).

Not applicable for the BUS right and capacity.

Record an uninsured balance of $0 for ABC Insurance Co.’s Annuitant Account under the Uninsured Amount field in the Account File.


ABC Insurance Co. Annuitants Account $0

8) The insured amount for each annuitant (in the ANC right and capacity) or each insurance company (in the BUS right and capacity) for the account is the difference between the funds in each right and capacity and the corresponding uninsured amount.

Not applicable for the BUS right and capacity.

Record an insured balance of $450,000 for ABC Insurance Co.’s Annuitant Account under the Insured Amount field in the Account File.


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ABC Insurance Co. Annuitants Account $450,000

9) Flag accounts that have been processed as insurance determination is completed.


C.11.1.3 Outcome

One (1) entry in the Customer File for ABC Insurance Company.

One (1) entry in the Account File for ABC Insurance Company’s account in the ANC right and capacity.

Two (2) entries in the Account Participant File, one each for Hope Rollins and Janet Collins.



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C.12 Public Bond Accounts

C.12.1 Scenario 1

C.12.1.1 Background

The CI holds three public bond accounts for three public bond issuers, Issuer A, Issuer B, and Issuer C. All three issuers are public units and all three accounts are non-interest bearing DDAs. The interests of the bondholders in each of the three public bond accounts are as follows:

Issuer A

Bondholder Total Balance

Matt Johnson – Bond Series 1 $140,000


Brian Casey $10,000

Mildred Jones $25,000

Total $295,000

Issuer B





Sally Larkin – Bond Series 1 $60,000

Total $300,000

Issuer C




Sally Larkin – Bond Series 2 $200,000

Rachel Peters $65,000

Total $515,000

Assume none of the issuers has any other account at the same CI.


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1) Identify all public bond accounts by unique combination of bondholder and bond issuer of the public bond account.

Unique combinations of bond issuer and bondholder are as follows:

Unique Combinations of Bond Issuer and Bondholder

Issuer A Issuer B Issuer C

Matt Johnson Matt Johnson Matt Johnson

Brian Casey Sally Larkin Sally Larkin

Mildred Jones

Rachel Peters

2) Aggregate the total balance and accrued interest by each unique combination of bondholder and bond issuer under the PBA right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Aggregate total balance and accrued interest for each unique combination of bond issuer and bondholder is as follows:

Issuer A


Matt Johnson $260,000

Brian Casey $10,000

Mildred Jones $25,000

Total $295,000

Issuer B



Sally Larkin $60,000

Total $300,000

Issuer C



Sally Larkin $200,000

Rachel Peters $65,000

Total $515,000

3) For the aforementioned aggregation:



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For the aggregated amount by bondholder and bond issuer under the PBA right and capacity:

Not applicable for Matt Johnson with Issuer A as his total balance exceeds SMDIA.

For all other combinations of bondholder and bond issuer, the total amount does not exceed SMDIA and the funds are fully insured.

Issuer A

Bondholder Total Balance Insured Amount Uninsured Amount

Brian Casey $10,000 $10,000 $0

Mildred Jones $25,000 $25,000 $0

Total $35,000 $35,000 $0

Issuer B


Matt Johnson $240,000 $240,000 $0

Sally Larkin $60,000 $60,000 $0

Total $300,000 $300,000 $0

Issuer C


Matt Johnson $250,000 $250,000 $0

Sally Larkin $200,000 $200,000 $0

Rachel Peters $65,000 $65,000 $0

Total $515,000 $515,000 $0

b) If the total balance and accrued interest do exceed SMDIA, then funds in excess of SMDIA are not insured.


Total balance of Matt Johnson with Issuer A exceeds SMDIA and the excess of $10,000 is uninsured.

Issuer A

Bondholder Balance Insured Amount Uninsured

Amount

Matt Johnson $260,000 $250,000 $10,000

Total $260,000 $250,000 $10,000

4) After going through steps 3a and 3b, determine the uninsured amounts for the unique combination of bondholder and bond issuer under the PBA right and capacity.


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Issuer A


Matt Johnson $260,000 $250,000 $10,000

Brian Casey $10,000 $10,000 $0

Mildred Jones $25,000 $25,000 $0

Total $295,000 $285,000 $10,000

Issuer B


Matt Johnson $240,000 $240,000 $0

Sally Larkin $60,000 $60,000 $0

Total $300,000 $300,000 $0

Issuer C


Matt Johnson $250,000 $250,000 $0

Sally Larkin $200,000 $200,000 $0

Rachel Peters $65,000 $65,000 $0

Total $515,000 $515,000 $0

5) For each combination of public bond issuer and bondholder, if there are uninsured funds under the PBA right and capacity, then:

Applicable for Issuer A and Matt Johnson as there is an uninsured amount of $10,000.

Not applicable for all other combinations of bond issuer and bondholder.

a) Apply the uninsured amount first to the accrued interest (if any) in all such accounts.

Not applicable as there is no accrued interest in Issuer A’s public bond account.

b) If there is an uninsured amount remaining after step a, determine the account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Apply the entire uninsured amount of $10,000 to this account as it is the only PBA account Matt Johnson has with Issuer A at the CI.


Not applicable.


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d) If after step c, there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account (or accounts) for which to apply the uninsured amount.

Not applicable.

e) Based on the above determination, determine the uninsured amount to each public bond account held by the bondholder with the bond issuer under the PBA right and capacity.

The uninsured amount for Matt Johnson for the public bond account he holds with Issuer A is $10,000.

6) Determine the total uninsured amount for each public bond account of each bond issuer based on results from Step 5 and record the uninsured amount for that public bond account in the PBA right and capacity.

Record an uninsured balance of $10,000 in the Account File under the Uninsured Amount field for Issuer A.

For Issuer B and Issuer C, the uninsured amount is zero.


Issuer A PBA $10,000

Issuer B PBA $0

Issuer C PBA $0

7) The insured amount for each individual account is the difference between the funds in the PBA right and capacity and the corresponding uninsured amount.

Record insured balances in the Account File under the Insured Amount fields as follows.


Issuer A PBA $285,000

Issuer B PBA $300,000

Issuer C PBA $515,000



C. 12.1.3 Outcome

Three (3) entries in the Customer File: one for each issuer (Issuer A, Issuer B, and Issuer C).

Three (3) entries in the Account File:

One entry for the funds from Issuer A public bond account in the PBA right and capacity.

One entry for the funds from Issuer B public bond account in the PBA right and capacity.

One entry for the funds from Issuer C public bond account in the PBA right and capacity.


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Eight (8) entries in the Account Participant File: one for each unique combination of public bond issuer and bondholder:

Bond Issuer Bond Holder

Issuer A Matt Johnson

Issuer A Brian Casey

Issuer A Mildred Jones

Issuer B Matt Johnson

Issuer B Sally Larkin

Issuer C Matt Johnson

Issuer C Sally Larkin

Issuer C Rachel Peters



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C.13 Custodian Accounts for American Indians

C.13.1 Scenario 1

C.13.1.1Background

The Bureau of Indian Affairs (“BIA”) holds a deposit account for two Native Americans at a CI with a total balance of $450,000 in a non-interest bearing DDA. The deposits held by the BIA at the CI are as follows:

Owner Total Balance

John Melvin $150,000

Eve Mendis $300,000

Total $450,000

Neither John Melvin nor Eve Mendis holds any other account at the CI.


1) Identify all Native Americans for which deposits of the account are held.

Deposits are held by the Bureau of Indian Affairs for John Melvin and Eve Mendis.

2) Determine the amount each Native American is entitled to in the account.

John Melvin is entitled to $150,000 and Eve Mendis is entitled to $300,000.

3) Aggregate the deposits across all BIA accounts each Native American holds at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

As the BIA account is the only account John Melvin and Eve Mendis hold at the CI, the aggregated deposits each holds are $150,000 and $300,000, respectively.

4) For the aggregated amount each Native American holds in the BIA right and capacity at the CI:

a) If the aggregated amount does not exceed SMDIA, then the funds are fully insured.

John Melvin’s total balance of $150,000 does not exceed SMDIA and his total funds are fully insured.

Owner Total Balance Uninsured Amount

John Melvin $150,000 $0

b) If the aggregated amount exceeds SMDIA, then funds in excess of SMDIA are not insured.

Eve Mendis’ total balance of $300,000 exceeds SMDIA by $50,000. The excess of $50,000 is uninsured.


Eve Mendis $300,000 $50,000

5) If there are uninsured funds for a Native American, then:

Not applicable for John Melvin as he does not have any uninsured funds.

Applicable for Eve Mendis as she does have an uninsured amount of $50,000.


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a) Apply the uninsured amount first to the accrued interest of all such accounts (if any)

Not applicable as this account does not have any accrued interest.


Apply the uninsured amount of $50,000 to this account as it is the only BIA account Eve Mendis holds at the CI.


Not applicable.


Not applicable.

6) Based on the above determination, determine and record the uninsured amount for each BIA account.

Record the uninsured balance of $50,000 for this BIA account as the sum of the uninsured amounts for John Mendis ($0) and Eve Mendis ($50,000) in the Account File under the Uninsured Amount field.


John Melvin $150,000 $0

Eve Mendis $300,000 $50,000

Total $450,000 $50,000

7) Determine the insured amount for each Native American as the difference between his or her interest in the account and the uninsured amount.

The insured amount is $150,000 (= $150,000 - $0) for John Melvin and $250,000 (= $300,000 - $50,000) for Eve Mendis.

Record an insured amount of $400,000 for this BIA account in the Account File under the Insured Amount field.

Owner Total Balance Insured Amount

John Melvin $150,000 $150,000

Eve Mendis $300,000 $250,000

Total $450,000 $400,000



C.13.1.3 Outcome

One (1) entry in the Customer File for the Bureau of Indian Affairs.

One (1) entry in the Account File for the Bureau of Indian Affairs’ account in the BIA right and capacity.

Two (2) entries in the Account Participant File, one each for John Melvin and Eve Mendis.


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C.14 Accounts of an IDI Pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy

C.14.1 Scenario 1

C.14.1.1 Background

Enfield Bank is a participant in the Bank Deposit Financial Assistance Program of the Department of Energy and has $275,000 in funds deposited at a CI and the account is held in CD. Of this $275,000, $5,000 represents accrued interest. Enfield Bank also holds another non-interest bearing DDA pursuant to the Bank Deposit Financial Assistance Program of the Department of Energy with a total balance of $50,000. Enfield does not hold any other account at the CI.


1) Identify the IDI and all accounts the IDI has under the DOE right and capacity at the CI.

Enfield Bank has two DOE accounts at the CI: one is the CD account with a total balance and accrued interest of $275,000, and the other is the non-interest bearing DDA account with a total balance of $50,000.

Account Product Type Total Balance

Enfield Bank DOE CD Account CD $275,000

Enfield Bank DOE DDA Account Non-Interest Bearing DDA $50,000

Total $325,000

2) Aggregate total account balance and accrued interest of each IDI for those accounts held in the DOE right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

Enfield Bank has a total balance and accrued interest of $325,000 in the DOE right and capacity at the CI.

3) For the aggregated account balance and accrued interest for each IDI:


Not applicable as the total balance and accrued interest does exceed SMDIA.


Total balance and accrued interest of $325,000 exceeds SMDIA by $75,000. The excess of $75,000 is not insured.

4) If there are uninsured funds for the IDI, then:


$5,000 of the total uninsured funds of $75,000 applies to the accrued interest of the CD account.

b) If there is an uninsured amount remaining after step a, determine the DOE account(s) of the IDI that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

There is a total of $70,000 uninsured amount remaining after step a, all of which will be attributed to the CD account based on the liquidity priority order.


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Not applicable.


Not applicable.

5) Based on the above determination, determine the uninsured amount of each DOE account the IDI has at the CI.

For the CD account, record the uninsured amount of $75,000 (= $5,000 + $70,000) in the Account File under the Uninsured Amount field.

For the DDA, record the uninsured amount of $0 in the Account File under the Uninsured Amount field.

Account Product Type Total Balance Uninsured Amount

Enfield Bank DOE CD Account CD $275,000 $75,000

Enfield Bank DOE DDA Account Non-Interest Bearing DDA

$50,000 $0

Total $325,000 $75,000

6) Determine the insured amount for each DOE account the IDI has at the CI as the difference between the sum of current balance and accrued interest and the uninsured amount.

For the CD account, record the insured amount of $200,000 (= $275,000 - $75,000) in the Account File under the Insured Amount field.

For the DDA, record the insured amount of $50,000 (= $50,000 - $0) in the Account File under the Insured Amount field.

Account Product Type Total Balance Insured Amount

Enfield Bank DOE CD Account CD $275,000 $200,000

Enfield Bank DOE DDA Account Non-Interest Bearing DDA

$50,000 $50,000

Total $325,000 $250,000


Flag both accounts as complete after the steps above are completed.

C.14.1.3 Outcome

One (1) entry in the Customer File for Enfield Bank.

Two (2) entries in the Account File, one for the CD account and the other for the DDA.




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C.15 Fiduciary Account - Broker/Sweep Accounts

C.15.1 Scenario 1

C.15.1.1 Background

Assume one day after bank failure, the CI has processed accounts for which it has necessary information and made insurance determinations. This includes the processing of Marci Jones’ single accounts in Section C.1.1 and the business accounts of XYZ Dredging, Inc. in Section C.7.1.

Recall Marci Jones had three single accounts at the CI with the following insurance determination:

Account Title Total Balance Insured Amount Uninsured Amount

Marci Jones (Savings Account) $55,000 $55,000 $0

Marci Jones DBA Marci's Cakes (a sole proprietorship, DDA Account)

$25,000 $25,000 $0

Marci Jones (CD Account) $200,000 $170,000 $30,000

Total $280,000 $250,000 $30,000

XYZ Dredging, Inc. had two business accounts at the CI with the following insurance determination:

Account Title Total Balance Insured Amount Uninsured Amount

XYZ Dredging, Inc. (CD account) $200,000 $200,000 $0

XYZ Dredging, Inc. (DDA account) $40,000 $40,000 $0

Total $240,000 $240,000 $0

C.15.2 Scenario 1 - Day 1

Assume on Day 1, the CI receives the following information from Anytown Broker:

Anytown Broker sweeps $2,000,000 in excess balances from customers’ brokerage accounts into a CD account at the CI. Anytown Broker’s deposit account meets the Alternative Recordkeeping Requirements as outlined in Part 370 and meets the FDIC’s definition for the fiduciary account. The sweep account of Anytown Broker represents a direct obligation brokered deposit at the CI. The beneficial owners of Anytown Broker’s deposit account are as follows:

Customer Customer Type Total Balance

Marci Jones Individual $150,000

XYZ Dredging, Inc. Business $100,000

Anywhere City Government $750,000

ABC Trust (Owned by Al Adams) Trust $1,000,000

Assume for simplicity, the amounts above represent the total balances of the beneficiary owners (i.e., no accrued interest).

Based on this information, the CI can make insurance determinations regarding Marci Jones’ and XYZ Dredging, Inc.’s ownership interest in this broker account. Sufficient information for Anywhere City and ABC Trust is not available for making an insurance determination. In addition, assume the CI does not hold any security pledge for Anywhere City.


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C.15.2.1.1 Anytown Broker Account

If an account meets FDIC’s definition of fiduciary account28

:

Applicable.


For Marci Jones, sufficient information is available on Day 1 to enable the insurance determination. Please see Section C.15.2.1.2 below for the insurance determination for Marci Jones.

For XYZ Dredging, Inc., sufficient information is available on Day 1 to enable the insurance determination. Please see Section C.15.2.1.3 below for the insurance determination for XYZ Dredging, Inc.


For all other beneficial owners, the information is pending from the broker. Please see Section C.15.2.2 below for the population of the Pending File.

3) If the account and principal(s) are placed in the Pending File, then determine the deposit insurance coverage upon obtainment of sufficient information based on the actual right and capacity of the funds held by the principal(s).

Not applicable.

15.2.1.2 Deposit Insurance Determination for Marci Jones (SGL)

The information provided by Anytown Broker to the CI on Day 1 indicates that Marci Jones’ interest in the sweep account represents funds she holds in the single account right and capacity. As indicated above, Marci Jones has three other single accounts at the CI for which the insurance determination has been completed. Assume for simplicity that her account total balance of $150,000 with Anytown Broker does not include any accrued interest.

Based on information above, the CI is able to complete the deposit insurance calculation for all funds Marci Jones holds in the SGL right and capacity on Day 1 based on the following deposit insurance determination algorithm for the SGL right and capacity.


Marci Jones is the only single account owner.

2) Aggregate total account balance and accrued interest by each unique account owner for those accounts held in the Single Account right and capacity. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

28

Fiduciary accounts are deposit accounts established by a person or entity (the fiduciary) for the benefit of one or more parties, also known as principals. Fiduciary accounts are not insured as a separate right and capacity and the deposit insurance coverage for such accounts depends on the actual right and capacity in which the principal or owner holds the funds. As a result, fiduciary accounts are added to the principal’s other accounts in the same right and capacity at the same CI for purpose of deposit insurance determination.


Page | 144

The aggregate total balance and accrued interest is $430,000 for all accounts in the SGL right and capacity owned by Marci Jones.

Note the aggregate amount represents the total funds Marci Jones holds in the SGL right and capacity across all four accounts at the CI.


Marci Jones Marci Jones Savings $55,000

Marci Jones DBA Marci's Cakes (a sole proprietorship) Marci Jones DDA $25,000

Marci Jones Marci Jones CD $200,000

Marci Jones (Anytown Broker) Marci Jones CD $150,000

Total

$430,000

3) For the aggregated account balance and accrued interest for each account owner

a) If the total balance and accrued interest does not exceed SMDIA, then the funds are fully insured and the insured amount for each account is equal to the sum of balance and accrued interest:

Not applicable, total balance and accrued interest of $430,000 exceeds SMDIA.





Not applicable.


Both Marci Jones’ CD account and funds Marci Jones holds in the SGL right and capacity through Anytown Broker are held as CDs.

Proceed to next step.


Apply the uninsured amount of $180,000 to Marci Jones’ CD account not held through Anytown Broker as it has a higher total balance ($200,000) than Marci Jones’ CD account held through Anytown Broker ($150,000).


Not applicable.

5) Based on the above determination, record the respective uninsured amount to each account for the account owner.


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Record the following uninsured balances for Marci Jones’ accounts held in the SGL right and capacity in the Account File under the Uninsured Amount field:

Account Title Deposit Type Uninsured Amount

Marci Jones Savings $0

Marci Jones DBA Marci's Cakes (a sole proprietorship) DDA $0

Marci Jones CD $180,000

Marci Jones (Anytown Broker) CD $0

Total

$180,000


Record the following insured balances for Marci Jones’ accounts held in the SGL right and capacity in the Account File under the Insured Amount field:

Account Title Deposit Type Insured Amount

Marci Jones Savings $55,000

Marci Jones DBA Marci's Cakes (a sole proprietorship) DDA $25,000

Marci Jones CD $20,000

Marci Jones (Anytown Broker) CD $150,000

Total

$250,000


Flag the sweep account as complete only after the insurance determinations for all beneficiary owners is completed.

Flag Marci Jones’ other three accounts held in the SGL right and capacity as complete after the steps above are completed.

C.15.2.1.3 Deposit Insurance Determination for XYZ Dredging, Inc. (BUS)

The information provided by Anytown Broker to the CI indicates that XYZ Dredging, Inc.’s interest in the sweep account represents its deposits in the business account right and capacity. As indicated above, XYZ Dredging, Inc. has two other business accounts at the CI. Assume for simplicity its account total balance of $100,000 with Anytown Broker does not include any accrued interest. NOTE: The broker only submits a principal balance in its submission file. The accrued interest is allocated based on the bank records.

Based on information above, the CI is able to complete the deposit insurance calculation for all funds XYZ Dredging, Inc. holds in the BUS right and capacity on Day 1 based on the following deposit insurance determination algorithm for the BUS right and capacity.


XYZ Dredging, Inc. is the account owner.

2) Aggregate total account balance and accrued interest of the corporation, partnership, or unincorporated association across all accounts the entity holds in the BUS right and capacity at the CI. If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).


Page | 146

The aggregate total balance and accrued interest is $340,000 for all accounts in the BUS right and capacity owned by XYZ Dredging, Inc.

Note the aggregate amount represents the total funds XYZ Dredging, Inc. holds in the BUS right and capacity across all three accounts at the CI.


XYZ Dredging, Inc. XYZ Dredging, Inc. DDA $200,000

XYZ Dredging, Inc. XYZ Dredging, Inc. DDA $40,000

XYZ Dredging, Inc. (Anytown Broker) XYZ Dredging, Inc. CD $100,000

Total $340,000


Not applicable as total balance and accrued interest of $340,000 exceeds SMDIA.





Not applicable.

b) Determine the business account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16

of this document).

Based on the liquidity priority order, the total uninsured amount of $90,000 is applied to XYZ Dredging, Inc.’s account held with Anytown Broker.


Not Applicable


Not applicable.

4) Based on the above determination, determine the uninsured amounts to each business account the corporation, partnership, or unincorporated association has at the CI.

Record an uninsured balance of $90,000 for XYZ Dredging, Inc. in the Account File under the Uninsured Amount field for this sweep account.

Record an uninsured balance of $0 for XYZ Dredging, Inc.’s other two business accounts.



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Record an insured balance of $10,000 (= $100,000 - $90,000) for XYZ Dredging, Inc. in the Account File under the Insured Amount field for this sweep account.

Record an insured balance of $200,000 and $40,000 for the other two DDAs, respectively.


Flag the sweep account as complete only after the insurance determinations for all beneficial owners are completed.

Flag XYZ Dredging, Inc.’s other two DDAs held in the BUS right and capacity as complete after the steps above are completed.

C.15.2.2 Outcome

As on Day 1, Anytown Broker provides customer information and account total balances for all beneficial owners (including Anywhere City and ABC Trust), the CI is able to populate the Output Files as follows:

Three (3) entries in the Customer File:

One entry for Anytown Broker.

One entry for Al Adams, the account owner of ABC Trust.

One entry for Anywhere City.

No entry for Marci Jones and XYZ Dredging, Inc. as the entries already exist in the Customer File.

Three (3) entries in the Account File:

One entry for Marci Jones’ interest in the single account right and capacity held with Anytown Broker.

One entry for XYZ Dredging, Inc.’s interest in the business account right and capacity held with Anytown Broker.

One entry representing the aggregate interest of Marci Jones and XYZ Dredging, Inc. in Anytown Broker’s account for which the insurance determination is completed. Set Right and Capacity = Null and DP_PT_Account_Flag = Y.

Update the entry previously entered for Marci Jones’ CD account held in the SGL right and capacity from Scenario C.1.1 to reflect the change in the insurance determination due to the additional funds Marci Jones holds in the SGL right and capacity through Anytown Broker.


Three entries in the Pending File:

One for the ABC Trust with Pending Reason Code ARB (direct obligation brokered deposit). Set PT_Parent_Customer_ID as the customer ID assigned to Anytown Broker.

One for Anywhere City with Pending Reason Code ARB (direct obligation brokered deposit). Set CS_Security_Pledge = N as the CI does not hold security pledge for Anywhere City. In addition, set PT_Parent_Customer_ID as the customer ID assigned to Anytown Broker.

One for the total ownership interest for the two beneficiary owners of the Anytown Broker account ($1,750,000) for which information is missing by using Pending Reason code ARB. Set Right and Capacity = Null and DP_PT_Account_Flag = Y.


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C.15.3 Scenario 1 - Day 15

C.15.3.1 Overview

Assume after 15 Days, Anytown Broker provides the following information regarding the remaining two beneficial owners to the CI.

Customer Customer Type Total Balance Beneficiaries/Official Custodians

Anywhere City Government $750,000 Harry Jones and Susan Doe

ABC Trust (Owned by Al Adams) Trust $1,000,000 Bob Adams and Chris Adams


C.15.3.2.1 Anytown Broker Account

If an account meets the FDIC’s definition of fiduciary account:

Applicable.


Not applicable for the two beneficial owners for whom the information is received 15 days after the bank failure.


Not applicable. The individual interests of these two beneficial owners has already been placed in the Pending File on Day 1 based on the customer and total balance information provided by the broker. Refer to Section C.15.2.2 above for details.

3) If the account and principal(s) are placed in the Pending File, then determine the deposit insurance coverage upon obtainment of sufficient information based on the actual right and capacity of the funds held by the principal(s).

Deposit insurance determination can be performed for each of these two beneficial owners based on information received on Day 15. See the sections below for details.

C.15.3.2.2 Deposit Insurance Determination for Anywhere City (GOV1)

The information provided by Anytown Broker to the CI indicates that Anywhere City’s interest in the sweep account represents the funds it holds in the government account right and capacity. Anywhere City has two custodians Harry Jones and Susan Doe. In addition, the CI is located in the same state as Anywhere City. Anywhere City does not have any other accounts at the CI and assume for simplicity its account total balance does not include any accrued interest. Assume the CI does not hold any security pledge for Anywhere City.

After receiving the additional information, the CI is able to complete the deposit insurance calculation for Anywhere City on Day 15 based on the following deposit insurance determination algorithm for the GOV1 right and capacity. A right and capacity of GOV1 is identified as the CI is located in the same state as Anywhere City and the account is held in CD (time and savings account).

1) Identify all unique combinations of official custodian, public unit, and government account ORCs (GOV1, GOV2, and GOV3).


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Based on the information provided, the unique combinations of official custodian, public unit, and government account ORCs (GOV1, GOV2, and GOV3) are as follows:

Public Unit Custodian(s) Deposit Type Right and Capacity

Anywhere City Harry Jones & Susan Doe CD GOV1

Note: For Anywhere City, GOV1 is for time and savings account held at the in-state CI, GOV2 is for demand deposit account held at the in-state CI, and GOV3 is for deposit account held at an out-of-state CI (regardless of the product type).

2) Aggregate total account balance and accrued interest by each unique combination of official custodians, public units, and government account ORCs (GOV1, GOV2, and GOV3). If this is a second or successive iteration of the Deposit Insurance Determination due to newly identified account(s), the accounts in the same ORC from the previous determination must be aggregated with the newly identified account(s).

The aggregate total balance and accrued interest for each combination is as follows:

Public Unit Custodian(s) Right and Capacity Total Balance

Anywhere City Harry Jones & Susan Doe GOV1 $750,000

3) For the each of the aggregated amounts above:

a) If the total balance and accrued interest does not exceed SMDIA times the number of official custodians, then the funds are fully insured

Not applicable.


The total funds do exceed SMDIA multiplied by 2 (= $500,000) and the excess of $250,000 is the uninsured amount.

Based on the above, the account insurance coverage is as follows:

Public Unit Custodian(s) Right and Capacity Total Balance Uninsured Amount

Anywhere City Harry Jones & Susan Doe GOV1 $750,000 $250,000


Applicable as Anywhere City has an uninsured amount of $250,000.

a) If the government entity has an outstanding security pledge with the CI, then place the account in the Pending File (see Section 4.2.9 of this document).

Not applicable.


Applicable as the CI does not hold a security pledge for Anywhere City.

i) Apply the uninsured amount to the accrued interests of all such accounts (if any).

Not applicable as there is no accrued interest in this sweep account.

ii) If there is an uninsured amount remaining after step i), determine the government account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).


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Apply the total uninsured amount of $250,000 to the ownership interest Anywhere City holds in this sweep account in the GOV1 ORC (as it is the only account Anywhere City holds deposits at the CI).

iii) If post step ii, there are multiple accounts with the same product type that exceed SMDIA, then apply the uninsured amount to the account with the highest total balance first.

Not applicable.

iv) If post step iii, there are multiple accounts with the same product type that exceed SMDIA with the same total balance, the CI should select an account for which to apply the uninsured amount.

Not applicable.


Record an uninsured balance of $250,000 for Anywhere City in the Account File under the Uninsured Amount field for this sweep account.


Record an insured balance of $500,000 (= $750,000 - $250,000) for Anywhere City in the Account File under the Insured Amount field for this sweep account.


Flag the sweep account as complete only after the insurance determinations for all beneficiary owners are completed.

C.15.3.2.3 Deposit Insurance Determination for ABC Trust (REV)

The information provided by Anytown Broker to the CI indicates that ABC Trust’s interest in the sweep account represents its deposits in the revocable trust account right and capacity and it names two primary beneficiaries Bob Adams and Chris Adams with equal share of the trust funds. ABC Trust’s owner, Al Adams, does not have any other trust accounts at the CI and assume for simplicity, his account total balance does not include any accrued interest. Neither Bob Adams nor Chris Adams has any other account at the CI.

After receiving the additional information, the CI is able to complete the deposit insurance calculation for ABC Trust on Day 15 based on the following deposit insurance determination algorithm for the REV right and capacity.


Al Adams is the account owner for the trust account.

ABC Trust has two primary beneficiaries: Bob Adams and Chris Adams.


Al Adams is the only account owner with two eligible unique primary beneficiaries, Bob Adams and Chris Adams.

3) Determine the allocations from each account owner to the eligible unique primary beneficiaries based on the information of the allocation of funds.


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Based on the beneficiary allocation information presented in the trust documentation, Al Adams’ eligible unique primary beneficiaries are allocated the following:


Bob Adams $500,000

Chris Adams $500,000

Total $1,000,000


The aggregate total balance and accrued interest of Al Adams is $1,000,000 based on step 3 above.


Applicable as Al Adams has two eligible unique primary beneficiaries and they have equal interests in the trust account.


Not applicable.


The total funds do exceed SMDIA multiplied by 2 (= $500,000) and the excess of $500,000 is the uninsured amount.


Not applicable.



Not applicable.


Not applicable.



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Not applicable.


Not applicable.


Not applicable.

8) If there are uninsured funds for the owner, then:

Applicable as there is an uninsured amount of $500,000.

a) Apply the uninsured amount to the accrued interest (if any) of all such accounts.

Not applicable.

b) If there is an uninsured amount remaining after step a, determine the revocable trust account(s) that will be uninsured following the liquidity priority order (see Section 4.2.16 of this document).

Apply the total uninsured amount of $500,000 to ABC Trust’s interest in this sweep account as it is the only account where ABC Trust holds deposits in the REV right and capacity at the CI.


Not applicable.


Not applicable.

9) Based on the above determination, record the respective uninsured amount of the owner to each associated account.

Record an uninsured balance of $500,000 for ABC Trust in the Account File under the Uninsured Amount field for this sweep account.


Record an insured balance of $500,000 (=$1,000,000 - $500,000) for ABC Trust in the Account File under the Insured Amount field for this sweep account.


Flag the sweep account as complete as the insurance determinations for all beneficiary owners are now completed.


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C.15.3.3 Outcome

After receiving complete information on the two beneficial owners for whom the insurance determinations can be completed as described above on Day 15. Populate the Output Files as follows:

No additional entry is needed in the Customer File.

Two (2) additional entries in the Account File; in addition to the entries created for Marci Jones, XYZ Dredging, Inc. and Anytown Broker on Day 1, create one entry for each of the two beneficiary owners on Day 15:

One (1) for Anywhere City’s deposit interest in the GOV1 right and capacity held with Anytown Broker.

One (1) for Al Adams’ deposit interest in the REV right and capacity held with Anytown Broker.

Update the entry for Anytown Broker on Day 1 to reflect the aggregate interest of all four beneficial owners for which the insurance determination is completed on Day 15.

For Anytown Broker’s account, DP_Allocated_Amt = DP_Total_PI = $2,000,000, DP_Uninsured_Amount =

$840,000 (= $0 for Marci Jones’ SGL account + $90,000 from XYZ Dredging, Inc.’s BUS account + $250,000 from

Anywhere City’s GOV1 account + $500,000 from Al Adam’s REV account), DP_Insured_Amount = $1,160,000 (=

$2,000,000 - $840,000).

Four entries in the Account Participant File:

Two (2) entries for the two official custodians of Anywhere City’s deposit interest in the GOV1 right and capacity (Harry Jones and Susan Doe).

Two (2) entries for the two primary beneficiaries of Al Adams’ ABC Trust account (Bob Adams and Chris Adams).

Pending File:

Remove the entries created on Day 1 for Anytown Broker, ABC Trust and Anywhere City.

After the completion of the insurance determination for all beneficiaries on Day 15, there is no entry in the Pending File for this sweep account.


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Appendix D Acronyms/Abbreviations/Terms

Acronym / Abbreviation Term

ANC Annuity Contract Accounts

ATF As Trustee For

BIA Custodian Accounts for American Indians

BUS Business/Organization Account

CD Certificate of Deposit

CDE Critical Data Element

CDIC Canada Deposit Insurance Corporation

CFR Code of Federal Regulations

CI Covered Institution

CIF Customer Information File

CRA Certain Retirement Accounts

DBA Doing Business As

DDA Demand Deposit Account

DIT CI as Trustee of Irrevocable Trust Accounts

DOE CI Accounts Under Department of Energy Program

EBP Employee Benefits Plan Account

ETIN Electronic Transmitter Identification Number

FDI Act Federal Deposit Insurance Act

FDIC Federal Deposit Insurance Corporation

GOV1 Government Account - Type 1



IDI Insured Depository Institution

IRA Individual Retirement Account

IRR Irrevocable Trust Account

IT System Information Technology System

ITF In Trust For

JNT Joint Account

MMDA Money Market Demand Account


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Acronym / Abbreviation Term

MSA Mortgage Servicing Account

NOW Negotiable Order of Withdrawal

OI Official Item

ORC Ownership Right and Capacity

P&I Principal and Interest

PBA Public Bond Account

POD Payable on Death

REV Revocable Trust Account

SAV Other Savings Account

SEP Simplified Employee Pension

SGL Single Account

SIMPLE Savings Incentive Match Plans for Employees

SMDIA Standard Maximum Deposit Insurance Amount

SSN Social Security Number

T&I Taxes and Insurance

TIN Tax Identification Number

Definitions

Please refer to Part 370 for definitions of capitalized terms not otherwise defined herein. The definitions below are only for terms that have been included, but not otherwise defined, in the Information Technology Functional Guide.

Term Definitions

Certificate of Deposit A savings certificate with a fixed maturity date, specified fixed interest rate and can be issued in any denomination aside from minimum investment requirements. A CD restricts access to the funds until the maturity date of the investment.

Critical Data Element Data that is essential to produce a successful output.

Customer Information File A system that consolidates customer account information and combines it with basic demographic information to create a current snapshot of a customer relationship.

Doing Business As A "fictitious business name," "trade name," or "assumed name."

Demand Deposit Account A Demand Deposit Account is a deposit that is payable on demand and for which the depository institution does not reserve the right to require at least seven days' written notice of an intended withdrawal. The following deposit types are included within the definition of Demand Deposit Accounts:

Checking (Non-Interest and Interest bearing)

http://www.investopedia.com/terms/m/maturitydate.asp

http://www.investopedia.com/terms/f/fixedinterestrate.asp

http://www.investopedia.com/terms/f/fixedinterestrate.asp

http://www.investopedia.com/terms/d/denomination.asp


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Term Definitions

Electronic Transmitter Identification Number

A 5-digit identification number assigned by the IRS to a participant in IRS e-file that performs activity of transmission and/or software development.

Individual Retirement Account

A retirement savings program for individuals to which yearly tax-deductible contributions up to a specified limit can be made. The amount contributed is not taxed until withdrawn.

Money Market Demand Account

A financial account that pays interest based on current interest rates in

the money markets. Negotiable Order of Withdrawal

A savings account from which withdrawals can be made by negotiable orders of withdrawal (functional equivalent of checks). This is an interest-bearing account for which the bank must reserve the right to require the depositor to provide at least seven days’ notice of his/her intent to withdraw funds.

Official Item An item that the bank issues with guaranteed funds. Also called Cashier’s check

Other Savings Account An interest-bearing deposit account held at a bank or another financial institution that provides a modest interest rate.

Simplified Employee Pension A SEP plan allows employers to contribute to traditional IRAs (SEP-IRAs) set up for employees.

Savings Incentive Match Plans for Employees

Savings Incentive Match Plan for Employees Individual Retirement Account, commonly known by the abbreviation "SIMPLE IRA", is a type of tax-deferred employer-provided retirement plan in the United States that allows employees to set aside money and invest it to grow for retirement.

Standard Maximum Deposit Insurance Amount (“SMDIA”)

As defined in 12 U.S.C. 1821(a)(1)(E), SMDIA is the maximum insured amount per depositor, per insured bank, for each account ownership category.

Social Security Number A nine-digit number assigned to citizens, some temporary residents and permanent residents in order to track their income and determine benefit entitlements.

Tax Identification Number A Taxpayer Identification Number (TIN) is an identification number used by the Internal Revenue Service (IRS) in the administration of tax laws.

Time and Savings Account The following deposit types are included within the definition of “Time and Savings”

NOW Account (these are deposits on which the depository institution has reserved the right to require at least 7 days written notice prior to withdrawal or transfer of any funds from the account)

Savings

Certificate of Deposit (CD)

Money Market Deposit Account (MMDA)

https://www.law.cornell.edu/uscode/text/12/1821#a_1_F


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References

Section Reference

Section 3.1 Deposit Insurance Coverage (12 CFR § 330)

Section 3.1 Method for determining deposit and other liability account balances at a failed insured depository institution. (12 CFR § 360.8)

Section 5 “Six-month Rule” (12 CFR § 330.4)

Documents

Information Technology Functional Guide · 2.5 Conceptual Systems Flow ... 8 Certification of Compliance ... About the Part 370 Information Technology Functional Guide