FDIC Proposes a Tune-Up to Big Banks’ Deposit Insurance Math
Published Date: 11/4/2026
Proposed Rule
Summary
The FDIC wants to update how big banks figure out deposit insurance, making rules clearer and fairer while cutting unnecessary paperwork. This affects large banks and aims to keep rules in line with inflation. People have until January 4, 2027, to share their thoughts before changes kick in.
Analyzed Economic Effects
7 provisions identified: 4 benefits, 2 costs, 1 mixed.
Remove 2M‑Account IT Build Requirement
The FDIC proposes to remove 12 CFR part 370 so banks that have two million or more deposit accounts would no longer be required to operate IT systems capable of calculating deposit insurance coverage within 24 hours after the FDIC is appointed receiver. Instead, the FDIC would rely on its own systems and these banks would instead fall under the amended 12 CFR 360.9 requirements.
Add ‘Larger Covered Institution’ & Data Rules
The proposal creates a new category called a "larger covered institution": any insured depository institution with at least $2 billion in deposits and two million or more deposit accounts. Larger covered institutions would have to collect and maintain complete depositor and customer data in a standard format, including 26 mandatory data fields for each account unless exemptions apply.
Specific Implementation Deadlines Set
An IDI that is a larger covered institution as of the effective date of the revised rule would have to comply with all §360.9 requirements other than provisional holds within six months after the effective date and comply with provisional hold requirements within 18 months after the effective date. The proposal also describes implementation periods for institutions that become larger covered institutions after the effective date (the text references an 18‑month period in one place and a 12‑month period for covered institutions that meet the larger threshold for two consecutive quarters).
Account‑Holder Notice for Transactional Accounts
For certain deposit accounts with "transactional features," larger covered institutions would need to either contractually require account holders to provide FDIC the information in a new Appendix I format within 24 hours after the FDIC is appointed receiver, or give the account holder a written disclosure describing that requirement. Certain account types (for example, mortgage servicer accounts, short‑term real estate closing accounts, Interest on Lawyers Trust Accounts, and some employee benefit plan accounts) are excluded from this requirement.
Provisional Holds Required for Larger Institutions
The proposal would require larger covered institutions to be able to place and remove provisional holds in the manner specified under 12 CFR 360.9, i.e., the provisional hold requirements currently in §360.9 would apply to these larger institutions even if they were previously subject to part 370 and had been released from §360.9.
Indexing Coverage Thresholds to Inflation
The proposal would index the thresholds that determine whether an institution is a covered institution (currently: at least $2 billion in deposits and either 250,000 deposit accounts or $20 billion in total assets) to inflation, but would not otherwise change the numeric thresholds.
Automatic Release When Below Threshold
The proposal would provide for automatic release from the requirements of §360.9 if an institution falls below the covered institution threshold for three consecutive quarters.
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Key Dates
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