FDIC Paperwork Renewal: Yawn, Comments by May!
Published Date: 3/4/2025
Notice
Summary
The FDIC wants to renew some important paperwork rules that affect state savings banks. They’re asking for your thoughts by May 5, 2025, to make sure the process stays smooth and fair. This won’t cost banks extra money but keeps things clear and organized for everyone involved.
Analyzed Economic Effects
3 provisions identified: 0 benefits, 1 costs, 2 mixed.
FACTA furnishers must maintain accuracy procedures; large burden
State nonmember banks that furnish information to consumer reporting agencies must adopt procedures to enhance recordkeeping and accuracy under Section 312 of the FACT Act (Regulation V, OMB No. 3064-0161). The FDIC estimates annual burden for these collections at 177,284 hours total: 2,820 respondents × 40 hours each = 112,800 hours for procedures, and 2,820 respondents × 98 responses per respondent × 14 minutes each = 64,484 hours for distribution of notices in third-party responses.
State savings banks must file conversion notices
If you operate an insured State savings association planning a mutual-to-stock conversion, you must file a notice of intent and provide the FDIC copies of documents filed with State and Federal banking or securities regulators (OMB No. 3064-0117). The FDIC estimates the annual burden for this collection is 1,250 hours total (5 respondents × 1 response each × 250 hours per response).
Breach response and customer-notification program requirements
State nonmember banks must maintain response programs that include customer-notification procedures for unauthorized access that could result in substantial harm or inconvenience (OMB No. 3064-0145). The FDIC estimates the collection’s annual burden at 13,166 hours total, broken down as: 9 policy/recordkeeping responses (24 hours each = 216 hours), 350 customer notices (36 hours each = 12,600 hours), and 350 incident notifications to the primary federal regulator (1 hour each = 350 hours); this is an increase from 11,580 hours in 2022.
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