federal deposit insurance corporation division of finance 1601

Federal Deposit Insurance Corporation Division of Finance 1601 Bryan Street, Dallas, TX 75201 Deposit Compliance Analysis Section First Quarter 2008 Dear Chief Executive Officer: The Federal Deposit Insurance Reform Act of 2005 resulted in significant statutory changes to the FDIC deposit insurance assessment program. In conjunction with the Reform Act changes, the FDIC has modified the assessable deposit reporting format; the modifications become mandatory with the March 2008 Call Report and Thrift Financial Report (“TFR”). The FDIC has updated the Interim Deposit Review Guide that was made available on FDICconnect in July 2007. The updated guide — the Interim Assessable Deposit Review Guide (“the Guide”) — is now available on FDICconnect. The Guide includes information on the FDIC’s Deposit Review Program, which has been streamlined in approach to allow the FDIC to periodically review each institution’s deposit reporting. The Guide does not create new data collection requirements; rather, it updates the FDIC’s long-standing deposit validation process to reflect the reporting modifications. The most significant modifications to assessable deposit reporting are the simplification of the Call Report and TFR lines used for the assessment computation and the introduction of average deposit reporting for determining the assessment base. FDIC assessments are now based on amounts reported on Call Report Schedule RC-O items 1-6, or TFR Schedule DI lines 510–560 (“assessment lines”). The focus of the new assessment lines is on deposits as defined in section 3(l) of the Federal Deposit Insurance Act (“FDI Act-defined deposits”) and deposit exclusions that are allowed to be taken for assessable deposit reporting purposes. The revisions continue to rely on the same definitions of reportable deposits that were in effect prior to the reporting format modifications. In order for your institution to accurately report and document its FDI Act -defined deposits, it should (1) identify its FDI Act-defined deposits and the systems that process these deposits; (2) inventory the systems that contain deposits; (3) record the deposit amounts; and (4) map the identified systems into your deposit reporting processes. The FDIC will periodically conduct a review of your institution’s Call Report/TFR assessment lines and of the corresponding deposit systems and documentation (“Deposit Review”) for a representative quarter. Please note that Deposit Reviews will be conducted electronically through FDICconnect (the e-business portal through which your institution’s quarterly assessment invoices are made available). Documents requested during a Deposit Review should be transmitted to the FDIC expeditiously; therefore, you should ensure that your institution has FDICconnect coverage at all times and has an effective contingency plan for FDICconnect coverage when there is a staff turnover or routine staff absence. If you or your staff have any suggestions for improving the content of the Guide, please send them to me at [email protected]. For questions about the Guide, please contact the FDIC’s Deposit Compliance Analysis Section (DCAS) by email ([email protected]) or by phone (972-761-2169). FDIC staff is available to assist institutions with documentation or mapping issues, on-site if necessary. Sincerely, David Wisnewski, Manager

Interim Assessable Deposit Review Guide It is the responsibility of insured depository institutions to accurately report assessable deposits and maintain the documentation to readily permit verification of the correctness of deposits reported for assessment purposes. It is the responsibility of the FDIC to verify the correctness of the assessable deposits reported through periodic review of supporting records and documentation. This Interim Assessable Deposit Review Guide is intended to help by assisting preparers of the Call Report or Thrift Financial Report in understanding and properly applying assessable deposit reporting standards as set forth in the Federal Deposit Insurance Act (FDI Act), the FDIC Rules and Regulation, the Call Report/Thrift Financial Report Instructions and this guide.

Interim Assessable Deposit Review Guide Overview Page 1 Chapter 1 Page 4 Deposit Identification and Reporting Chapter 2 Page 8 Allowable Exclusions (including Foreign Deposits) and Other Exclusions Chapter 3 Page 12 The Deposit Review Program Chapter 4 Page 18 Using the Deposit Recap and Average Summary Chapter 5 Page 29 FDICconnect and Examination File Exchange (EFE) Appendix 3 Sample Documentation Package

Interim Assessable Deposit Review Guide

1

Overview

The Assessable Deposit Review Guide (“the Guide”) is designed to help insured institutions better understand the FDIC’s longstanding reporting, documentation, and verification requirements associated with deposit reporting for FDIC assessments purposes. Insured institutions are required to accurately report deposits and to maintain supporting documentation. All institutions are subject to a periodic review by the FDIC of supporting records and documentation for the deposit amounts reported (“Deposit Review”). The Guide is intended to be a resource to help an institution identify all of its deposits, report its deposits accurately, and determine what documentation needs to be maintained to readily permit verification of the correctness of deposits reported for assessment purposes. The Guide also describes the Deposit Review process and offers insights on documentation that could help an institution successfully substantiate the deposits it reports to the FDIC for its assessment computation. Chapter 1 – Deposit Identification and Reporting Chapter 1 contains information that may help an institution identify all of its deposit liabilities and the associated systems of record that maintain and document those deposits. This chapter contains insights on effective internal control procedures related to deposit reporting. The FDIC offers suggestions on how to identify deposits that may not necessarily immediately come to mind when reporting assessable deposits. This chapter also provides guidance on how to report deposits on the Call Report/Thrift Financial Report (TFR) “assessments lines” (Call Report Schedule RC-O items 1-6 and TFR Schedule DI lines 510-560), including the requirements associated with quarter-end deposit reporting and average daily balance deposit reporting. This section gives specific reporting guidance to institutions that own a bank/thrift subsidiary. Chapter 2 – Allowable Exclusions (including Foreign Deposits) and Other Exclusions The starting point of deposit reporting for assessment purposes is “reported gross deposits” (Call Report Schedule RC-O items 1 & 4, and TFR Schedule DI lines 510 & 540). However, certain deposits are excludable from the initial gross deposit total resulting in the assessable deposits for the institution. Chapter 2 provides information on the two types of exclusions--Allowable Exclusions and Other Exclusions--and offers suggestions on how to effectively document and identify all exclusions to which an institution is entitled. Allowable Exclusions are types of deposits which by law or regulation are excluded from assessable deposits. One of the objectives of a Deposit Review is to verify exclusions are reported correctly and an institution has documentation to support all exclusions claimed. If exclusions are claimed, the documentation must be complete and readily available or the exclusion will not be allowed. The documentation should identify the type of deposit and support the amount of the exclusion. Other Exclusions are non-deposit amounts included as reported gross deposits on the Call Report/TFR assessment lines that can be excluded from the assessable deposit totals. Examples of Other Exclusions are credit-line accounts and institution-owned deposit accounts that are


2

sometimes recorded on Demand Deposit Account (DDA) systems. The documentation for any Other Exclusion should include a written explanation that describes the system from which it is derived, states the basis for exclusion from assessable deposits, and supports the amount of the exclusion. Foreign Deposits, in general, are deposits that are not payable in the United States or its territories. This chapter discusses how to report and document Foreign Deposits. Chapter 3 – The Deposit Review Program Every institution, regardless of its size, will at some point be involved in a FDIC Deposit Review. Chapter 3 describes the overall objectives of the Deposit Review Program, and describes in some detail how the process works. The Deposit Review process evaluates the effectiveness of an institutions’ deposit reporting internal controls taking into consideration the accuracy of the amounts reported on the assessment lines, the completeness and availability of documentation, and the timeliness of Deposit Review requests for documentation. At the end of the Deposit Review, a report will be issued to the institution’s CEO. By gaining an insight on how a Deposit Review works, the Deposit Review documentation requirements, and the roles of the FDIC and the institutions under review, an institution may be better able to integrate the Deposit Review requirements into its internal control processes. The Deposit Review is a structured process that considers the time necessary to provide documentation as part of the evaluation. The Deposit Review will primarily be conducted electronically through the Examination File Exchange (EFE) feature of FDICconnect. Therefore, it will be crucial for an institution to be diligent in maintaining its reporting control processes each quarter, and to make sure that its FDICconnect Coordinator and User functions are properly staffed. Special note for institutions that report daily average deposits: The FDIC recognizes the need to learn more about institutions’ daily average deposit reporting processes. During 2008, if an institution that reports daily average deposits is selected for a Deposit Review and is unable to produce the supporting documentation for the computation of the daily average balances for each day, it should contact DCAS. During 2008, the FDIC will work with the institution to validate their reported daily average deposits using other acceptable methods. If an institution that reports daily average deposits is selected for a Deposit Review, and has processes in place to produce the documentation to support the daily average deposits, it should submit the documentation as per the Guide.


3

Chapter 4 – Using the Deposit Recap and Average Summary The FDIC has developed a Deposit System Control Summary Recap (“Deposit Recap”) and a Gross Total Average Deposit Reporting Summary (“Average Summary”) that may be helpful for an institution to use to compile the amounts reported on its Call Report/TFR assessment lines. These formats may also be a useful internal self assessment control tool, and may be an effective deposit inventory tool that meets the FDIC’s Deposit Review expectations. Chapter 4 contains sample formats, and detailed guidance for their use. Chapter 5 – FDICconnect and Examination File Exchange (EFE) Chapter 5 contains a description of the FDICconnect and Examination File Exchange (EFE) roles in the Deposit Review process. This chapter contains detailed step-by-step instructions for signing up for FDICconnect, assigning personnel EFE access, and using EFE. Appendix – Sample Documentation Package The Appendix contains a narrative on how to complete the Deposit Recap and Average Summary discussed in Chapter 4. This section demonstrates how to use the formats using mock-up data that demonstrates common types of situations that an institution may encounter when reporting and documenting deposits. (The Appendix does not demonstrate every type of deposit or exclusion an institution may have) This section provides tips on how to report various types of deposits and provides suggestions for effective documentation practices. Outreach and Additional Information The FDIC conducts an outreach program that includes educational and communication initiatives applicable to deposit reporting topics of interest. The audiences for these outreach activities include individual institutions, financial industry groups, and the financial institution regulatory agencies. The FDIC also responds to assessable deposit reporting issues and questions from insured institutions through a designated e-mail and phone number: [email protected] or (972)761-2169. We hope the following chapters and appendix help your institution understand the expectations regarding assessable deposit reporting and help facilitate your efforts to maintain sound controls and determine appropriate documentation to substantiate your reported deposits. Completing the Deposit Recap and the Average Summary is not required but could expedite a Deposit Review of your institution. Institutions that do not use the Deposit Recap and Average Summary are encouraged to develop their own formats that contain the required Deposit Review documentation elements. This Guide will be updated as needed, so we encourage all insured institutions to send us comments and suggestions for improving the content or presentation to [email protected] .


4

Chapter 1 – Deposit Identification and Reporting Throughout the history of the FDIC, insured institutions’ assessments have been based on total domestic deposits. The definition of the term “deposit” is contained in section 3(l) the Federal Deposit Insurance Act (“FDI Act”) and includes a broad range of “funds held” by an institution. Generally, funds held by an institution but not owned by the institution (including any interest accrued on those funds) are deposits. Commercial banks report deposits on their Call Reports and thrifts report deposits on their TFRs (Thrift Financial Report), from which the FDIC computes their quarterly assessments. Deposits reported on the Call Report/TFR are derived from the “systems of record” that account for each deposit by an institution at the individual depositor level. This chapter includes information on how to identify all deposits (and their systems of record) held by an institution, Call Report/TFR deposit reporting requirements, and special instructions for institutions that own another bank or thrift as a subsidiary. Deposit Identification Some deposits and their systems of record are easier to identify than others. Ensure that all deposits and their systems of record are included in deposits reported. Most funds held by an institution that meet the FDI Act definition of deposit and their associated systems of record are intuitively recognizable, but some are not as readily recognizable. For instance, funds held in checking accounts, money market accounts, NOW accounts, etc., are readily recognized as deposits, and their system of record is usually the DDA (Demand Deposit Account) system. Other examples of commonly recognized deposit items are time deposits, savings accounts, certificates of deposits (CDs), and individual retirement accounts (IRAs). The system of record for these deposits is usually a conventional deposit processing system that also includes the accrued and unpaid interest (which is also considered a deposit). On the other hand, some funds held by an institution are not as intuitively recognized as deposits. These funds can be maintained in automated systems of record not normally associated with deposits or in manual systems of record. For instance, employee withholdings meet the definition of a deposit, but may not be typically recognized as deposits because their system of record is the payroll system. Pooled deposits associated with mortgage escrows, loan servicing, stored value or credit cards, and brokered CDs, often involve multiple accounts and depositors which may not be separately recognized when reporting these funds on the Call Report/TFR. The following are some of the most common items meeting the definition of a deposit that may be overlooked: • Mortgage Loan Escrows (i.e. Tax and

Insurance) • Official and Other Outstanding Checks • Treasury Tax and Loan (TT&L) • Travelers Checks & Money Orders Sold

• Funds held from the sale of Mutual Funds or Other Securities

• Backup Withholding • Security Deposits • Matured CDs • Employee Payroll Deductions


5

• Refundable Loan Fees • Unremitted Loan Participation Payments • Stale Dated Checks • IPS, Moneygram, etc.

• Uninvested Trust Funds • Credit Balances on Credit Cards • Accrued and Unpaid Interest on Escrows • Stored Value Cards (aka Gift Cards)

When preparing its Call Report/TFR, an institution must ensure all systems that process or record items that meet the FDI Act definition of a deposit are identified, the deposits associated with each system of record are reported on the Call Report/TFR, and the amounts reported are properly documented. These systems may be a manual process or an automated deposit processing platform used to track, control, and handle inquiries from depositors about their specific account. Understanding the nature of the financial transaction with a customer is helpful in ensuring that all deposits are identified and reported correctly. A systematic approach to identifying deposits and their systems of record should be integrated into an institution’s internal control processes. Some institutions include personnel from deposit operations and from other departments (i.e. trust, payroll, loans, etc.) in the deposit reporting process because they are familiar with their respective systems. External deposit servicers who are familiar with deposit systems may also be able to provide valuable assistance and support. Deposit Reporting - Quarter-end and Daily Average All institutions report their assessable deposits as of the end of the quarter. Large institutions ($1 billion or more in assets) and all institutions that became insured on or after March 31, 2007, also report their assessable deposits on a daily average basis (daily average reporting is optional for all other institutions). When an institution also reports daily average balances, the averages are used for the assessment computation. There are two components of deposit reporting for assessment purposes: “Quarter-end” and “Daily Average” reporting. All institutions are required to report quarter-end deposits. Institutions with $1 billion or more in assets as well as all new institutions (defined as those insured on or after March 31, 2007) are required to report daily average deposits in addition to quarter-end deposits effective with the March 31, 2008, Call Report/TFR.1 An institution that has less than $1 billion in assets and is not a newly insured institution may choose to report daily average deposits, which will be used to determine its assessment base. Once an institution begins reporting daily averaging deposits, it may not revert back to reporting only quarter-end deposits. There are three reporting elements for both quarter-end reporting and daily average balance reporting: (1) total gross deposits before exclusions, (2) total allowable exclusions (including foreign deposits) and other exclusions; (3) total gross foreign deposits. For quarter-end 1 The daily averages reported in the first report a new institution files after becoming insured should include the deposit totals for the days since the institution began operations and zero for the days prior, effectively pro-rating the first quarter’s assessment base.


6

reporting, these amounts are reported on a “snapshot” basis as of the last business day of the quarter. For daily average balance reporting, these amounts are calculated by adding the deposit totals for each calendar day during the quarter and dividing those amounts by the number of calendar days in the quarter. The use of daily average balances may provide a more representative depiction of an institution’s deposits. In addition, if an institution’s assessment base is growing, reporting average daily balances could result in smaller assessments. Call Report/TFR Assessment Lines FDIC assessments are based on deposits reported on Schedule RC-O of the Call Report (items 1 – 6) and on Schedule DI of the TFR (lines 510 – 530). Other deposit-related line items are not used in the assessment computation. Reporting deposits for assessment purposes is done on the Call Report Schedule RC-O, items 1, 2 and 3 (quarter-end deposits) & 4, 5, and 6 (daily average deposits) or the TFR Schedule DI, lines 510, 520, and 530 (quarter-end deposits) & lines 540, 550, and 560 (daily average deposits) collectively referred to as the “assessment lines.” Normally, the amounts to report on the assessment lines are typically found within the deposit systems of record and are supported by each system’s control totals. The system’s control totals should be readily available for verification by the FDIC. For assessable deposit purposes, deposits should be reported at gross (i.e., no “netting” or reduction of deposits due to another kind of transaction). For example, overdrafts affecting DDA or trust accounts and negative escrows should not be netted against the deposit totals. The Call Report and TFR have several deposit line items that are used for various regulatory purposes, such as Call Report Schedules RC, RC-E, RC-K and TFR Schedule SC710. Since these line items are designed with other purposes in mind, an institution should not necessarily expect them to directly correlate with the amounts reported on the assessment lines of Call Report Schedule RC-O and TFR Schedule DI. The Call Report Schedule RC-O and TFR Schedule DI assessment lines are distinct from the other Call Report/TFR deposit line items. Special Instructions for Institutions that have a Bank or Thrift Subsidiary Institutions with a Bank/Thrift Subsidiary: FDIC assessments are charged to each individually chartered institution based on its own Call Report/TFR assessment lines. Combining a FDIC insured subsidiary institution’s deposits with a parent institution’s deposits on its assessment lines will result in double assessment of the subsidiary institution’s deposits. There are a few insured banks and thrifts that own another separately chartered FDIC insured bank or thrift, and operate it as a subsidiary. In such cases the “parent bank or thrift” may combine the subsidiary bank or thrift’s customers’ deposits on the parent’s Call Report/TFR. Because the subsidiary institution is a separately chartered bank or thrift, it also prepares a Call


7

Report/TFR to report its own deposits, which results in the subsidiary bank or thrift’s customers’ deposits being reported on two Call Reports/TFRs: its own and the parent’s. Since each separately chartered institution has a unique assessment rate, the FDIC is required to assess each insured institution separately. If the subsidiary bank or thrift’s customers’ deposits are included on the assessment lines of the parent’s Call Report/TFR, the subsidiary bank’s deposits would be assessed twice. In order to avoid paying duplicate assessments, both the parent institution and subsidiary bank or thrift should each report only its own deposits and allowable exclusions on the assessment lines (Call Report Schedule RC-O items 1-6 or TFR Schedule DI lines 510 – 560). Chapter Summary The term “deposit” is defined by the FDI Act. The definition includes most funds held by an institution that do not belong to itself. When completing its Call Report/TFR assessment lines, an institution should be diligent in reporting all deposits (some deposits are more readily recognized than others). Large institutions (those with assets of $1 billion or more) and new institutions report both quarter-end deposit and daily average balances for the quarter. For all other institutions, daily average balance reporting is optional. When daily average balances are reported, they are used for the assessment computation.


8

Chapter 2 – Allowable Exclusions (including Foreign Deposits) and Other Exclusions

Certain “reported gross deposits” are excludable from an institution’s assessable deposits. Documentation for such exclusions must be readily available for FDIC verification. When reporting total deposit liabilities before exclusions on Call Report Schedule RC-O, Items 1 & 4, or TFR Schedule DI lines 510 & 540 (“reported gross deposits”), all amounts recorded on systems of record containing deposits are included. Certain deposits are allowed to be excluded from an institution’s assessable deposits by law and/or FDIC regulation; these are Allowable Exclusions. (Generally, deposits payable outside of the United States (Foreign Deposits) can be excluded from an institution’s assessable deposits as Allowable Exclusions.) Non-deposit amounts that do not meet the definition of deposits per the FDI Act that were included with the reported gross deposits can also be excluded from an institution’s assessable deposits; these are Other Exclusions. Supporting Documentation Supporting documentation that specifically identifies the type and nature of the exclusion must be maintained and readily available so that the exclusion(s) being reported can be verified. The inability of an institution to provide documentation to support the reported exclusion(s) may result in losing the right to the exclusion. The initial request for documentation for a Deposit Review will require that the following are identified: the control total page from the system of record from which the exclusion amount is derived, the number of accounts associated with the exclusion, and the total exclusion amount. Subsequent follow-up documentation requests may include such things as check copies, account statements, account agreements, investment contracts, pass-thru or correspondent agreements, and loan agreements, to provide additional support of a reported exclusion during a deposit review. Allowable Exclusions Any Allowable Exclusion amounts that are included with reported gross deposits on Call Schedule RC-O items 1& 4 or TFR Schedule DI lines 510 & 540, should be reported on Call Report RC-O items 2 & 5, or TFR lines DI 520 & 550. Allowable Exclusions are types of deposits which by law or regulation may be excluded from assessable deposits. Call Report Schedule RC-O item 2 and TFR Schedule DI item 520 are used to report quarter-end allowable exclusions. Daily average exclusions are reported on Call Report Schedule RC-O item 5 and TFR Schedule DI item 550. Any items eligible for exclusion must have been included with the reported gross deposits in order to be deducted from the assessment base computation. The allowable exclusions are listed and described as follows:


9

Reciprocal balances – Reciprocal balances result when two depository institutions maintain deposit accounts with each other. In this relationship a reporting institution has both “due to” and “due from” accounts with another depository institution. An institution may exclude any demand deposit balance due from or cash item in the process of collection due from any depository institution (not including a private depository institution, a foreign depository institution, a foreign office of another U.S. depository institution, or a U.S. branch of a foreign depository institution) up to the total of the amount of deposit balances due to and cash items in the process of collection due to the other depository institution. Drafts drawn on other depository institutions – Any outstanding drafts drawn on funds held in another institution (not to include a Federal Reserve Bank or Federal Home Loan Bank) by the reporting financial institution can be excluded from an institution’s assessable deposits. For example some institutions issue drafts (checks) drawn on their account at a larger correspondent bank. Pass-through reserve balances – Reserve balances passed through to the Federal Reserve, by the reporting institution, that are reflected as deposit liabilities of the reporting institution. This exclusion is not applicable to an institution that does not act as a correspondent bank in a pass-through reserve balance relationship. A state nonmember bank generally cannot act as a pass-through correspondent unless it maintains an account for its own reserve balances directly with the Federal Reserve. Depository institution investment contracts – Liabilities arising from depository institution investment contracts that are not treated as insured deposits under section 11(a)(5) of the Federal Deposit Insurance Act (12 U.S.C. 1821 (a)(5)). A Depository Institution Investment Contract is a separate negotiated agreement between an employee benefit plan and an insured institution that guarantees a specified rate for all deposits made over a prescribed period and expressly permits benefit responsive withdrawals or transfers. Hypothecated deposits – Deposits accumulated for the payment of personal loans that are assigned or pledged to assure payment of the loans at maturity. If carried as a deposit liability and included in the reported deposit totals, they qualify as an exclusion. Deposits that simply serve as collateral for loans are not allowable exclusions. Unposted Items - For the purposes of deposit and exclusion reporting, unposted items are defined as those deposit account transactions or items where no attempt to post to the associated deposit account(s) has been made. These items are typically cleared the next business day and normally do not materially affect the assessment base. Unposted debits should not reduce assessable deposits and unposted credits should not increase assessable deposits. Other Exclusions Any Other Exclusion amounts that are included with reported gross deposits should be reported on Call Report RC-O items 2 & 5, or TFR lines DI 520 & 550.


10

Other Exclusions are non-deposit amounts that have been included with reported gross deposits and can be excluded from an institution’s assessment base. Other Exclusions usually are a result of non-deposit items being processed and accounted for on a deposit system. Examples of Other Exclusions are credit line accounts and institution-owned deposit accounts that are sometimes recorded on DDA systems. The documentation for any Other Exclusion must include a written explanation within a Deposit Review documentation package that describes the system used for non-deposit purposes and states the basis for exclusion from reported assessable deposits. Foreign Deposits Foreign Deposits that are included with reported gross deposits should be reported on Call Report RC-O, items 2 and 3 & items 5 and 6, or TFR lines DI 520 and 530 & DI lines 550 and 560. Foreign Deposits as defined in Section 3(l) (5) of the FDI Act (Federal Deposit Insurance Act) can be excluded from an institution’s assessable deposits. Foreign Deposits are included with Allowable Exclusions, and also reported separately on their own Call Report/TFR lines (Call Report Schedule RC-O items 3 & 6, and TFR Schedule DI lines 530 & 560). Section 3(l) of the FDI Act states that the following shall not be a deposit:

(A) any obligation of a depository institution which is carried on the books and records of an office of such bank or savings association located outside of any state, unless – (i) such obligation would be a deposit if it were carried on the books and records of the depository institution, and would be payable at, an office located in any state; and (ii) the contract evidencing the obligation provides by express terms, and not by implication, for payment at an office of the depository institution located in any State. . .

Section 7(a)(4) of the FDI Act states that each institution:

shall report the total amount of the liability of the depository institution for deposits in the main office and in any branch located in any State of the United States, the District of Columbia, any Territory of the United States, Puerto Rico, Guam, American Samoa, the Trust Territory of the Pacific Islands, or the Virgin Islands . . .

If an institution is affiliated with a foreign bank but does not own the foreign bank, that foreign bank’s deposits would not be included with the institution’s reported gross deposits, and would not be included with allowable exclusions reported on Call Report Schedule RC-O, items 2 & 5 or TFR Schedule DI-530 & 550, nor would they be separately reported on Call Report Schedule RC-O, items 3 & 6, or TFR Schedule DI lines 530 & 560. International Banking Facility (IBF) deposits are also treated as Foreign Deposits, including IBF time deposits. An IBF is a set of asset and liability accounts segregated on an institution’s books


11

and records that includes only IBF time deposits and IBF extensions of credit. IBF time deposits and IBF extensions of credit are narrowly defined and restricted by the Board of Governors of the Federal Reserve System. An institution may establish an IBF as long as it is legal in the location in which it is established. An establishing institution must notify the Federal Reserve bank of the district in which the IBF is going to be established beforehand, and must state that it will comply with IBF restrictions and recordkeeping and accounting requirements. For an IBF’s deposits to be eligible as an Allowable Exclusion, the IBF must comply with all of the requirements set forth in the Federal Reserve System’s Regulation D. Chapter Summary Certain amounts included in reported gross deposits are excludable from an institution’s assessment calculation. Allowable Exclusions (including Foreign Deposits), and Other Exclusions, are reported on separate Call Report/TFR lines that are then deducted when the FDIC computes an institution’s quarterly assessment. All exclusion amounts must be substantiated by supporting documentation.


12

Chapter 3 – Deposit Review Program Each institution’s assessable deposit reporting is periodically validated by the FDIC through a “Deposit Review.” Periodically, an institution’s assessable deposit reporting will be validated by the FDIC’s Deposit Compliance Analysis Section (DCAS) for a selected quarter through the Deposit Review Program (a “Deposit Review”). Typically, a Deposit Review will occur after the Call Report/TFR under review has been filed and the assessment payment for the period associated with that Call Report/TFR has been collected. (For instance, under most circumstances an institution’s March Call Report/TFR would not be subject to a Deposit Review until after June 30.) At the end of the Deposit Review, a written report is issued to the institution’s Chief Executive Officer (CEO) that conveys the FDIC’s opinion on the effectiveness of the institution’s deposit related internal control and reporting practices by evaluating the level of deposit reporting compliance with (1) the statutory definition of deposits as contained in Section 3(l) of the FDI Act, (2) the assessment regulations contained in Part 327 of the FDIC’s Rules and Regulations, (3) the Call Report/TFR Instructions, and (4) the Interim Assessable Deposit Review Guide. Deposit Reviews are conducted electronically through FDICconnect. Deposit Review Elements The goal of the Deposit Review Program is to improve deposit reporting industry-wide by monitoring reported deposits, ensuring uniform compliance with deposit reporting requirements, and confirming the adequacy of internal controls relative to deposit and exclusion documentation and reporting. Accurate reporting ensures deposit insurance premiums--assessments--are correct. Through the Review Program DCAS evaluates the performance of an institution’s deposit-related internal control and reporting practices by reviewing the following elements:

• The accuracy of the assessment lines reported on a specific quarter’s Call Report/TFR. • The validity of the total number of accounts associated with the amounts reported on the

assessment lines. • The validity of all deposit exclusions. • The availability and completeness of supporting documentation. • The timeliness of providing documentation through FDICconnect and EFE.2

DCAS periodically tests the effectiveness of an institution’s deposit-related internal control and reporting practices by reviewing the accuracy of deposits reported for one selected quarter. Basically, the Deposit Review process compares an institution’s Call Report/TFR reported gross deposits and exclusions to the documentation from the deposits’ specific “systems of record.” (A deposit’s “system of record” is the system, automated or otherwise, that accounts for the

2 EFE (Examination File Exchange) is a FDICconnect based secure electronic format for institutions and the FDIC to exchange information and documentation.


13

deposit at the individual depositor level.) The documentation is examined to determine if all assessable deposits are being routinely included in an institution’s assessable deposits. Deposit Reviews are conducted electronically through FDICconnect with documentation being submitted or shared through the EFE (Examination File Exchange) feature of FDICconnect. When notified of a Deposit Review, an institution will be asked to transmit to the FDIC the documentation that substantiates amounts reported on its Call Report/TFR assessment lines (Call Report Schedule RC-O, item 1 – 6, and TFR Schedule DI lines 510 – 560). The FDIC does not mandate the method an institution uses to accumulate, reconcile, and control the assessable deposit amounts reported on the assessment lines. However, an institution’s chosen method for reporting assessable deposits should be fully supported by the deposit amounts as summarized in the associated systems of record. Deposit Review Process Deposit Reviews are conducted electronically through FDICconnect. Every institution should have an active FDICconnect coordinator and FDICconnect authorized users that know how to use EFE. The Deposit Review is a fairly structured process accomplished by exchanging information between an institution and the FDIC through the EFE component of FDICconnect. An institution should have an active FDICconnect Coordinator and a succession plan for prompt replacement of the designated Coordinator. In addition, an institution should have at least one FDICconnect user that is able to use EFE. The FDIC expects the FDICconnect Coordinator to facilitate and monitor the Deposit Review activities within the institution. Every institution is responsible for maintaining continuous FDICconnect and EFE coverage. See Chapter 5 for more information on FDICconnect and EFE. An institution will be asked to submit three specific documentation elements to the FDIC at the onset of the Deposit Review. (Institutions that report daily average deposits will be asked to submit four elements.) An engagement letter will be transmitted to an institution via FDICconnect that will ask for supporting documentation for amounts reported on the assessment lines. To fulfill this request, an institution should initially transmit the following: • An inventory listing (similar to the Deposit Recap described in Chapter 4) of each system of

record that contains deposits and exclusions—if any—included in the Call Report/TFR assessment lines, and contains the following information for each system (including subsystems) of record: (1) total gross deposits (2) the number of accounts (3) accrued and unpaid interest (4) overdrafts.


14

• A control total page for each system of record on the inventory listing (for example, a DDA system control summary report or a Trust Cash Trial Balance recap report). If depositors’ names are on the control pages, the names can be redacted.

• An unconsolidated general ledger balance sheet for the date being reviewed. • A listing that documents the computation of the daily average reported gross deposits for

each day of the calendar quarter if the institution reports gross daily average deposits (similar to the Average Summary described in Chapter 4). If an institution does not report average deposits this listing is not applicable.

Note: If an institution selected for review has processes in place to produce the required supporting documentation of the daily average reported gross deposits, they should submit the documentation as per the Guide.

The FDIC recognizes the need to learn more about daily average reporting processes. During 2008, if an institution selected for review is unable to produce the supporting documentation for the computation of the daily average balances for each day requested, they should contact DCAS. During 2008, the FDIC will work with the institution to validate their reported average balances using other acceptable methods. For example, officials at one institution informed the FDIC that they will use their general ledger process to identify their systems and sub-systems that contain deposit amounts; they also informed the FDIC that supporting documentation was more readily available for the quarter-end date than the intervening business days of the quarter.

Deposit Review Steps Step 1: The review begins with an e-mail notice from the FDIC to an institution’s assigned FDICconnect Coordinator advising the institution that a Deposit Review engagement letter has been posted on FDICconnect. Step 2: The Coordinator downloads the Deposit Review engagement letter. This letter states that the institution has been selected for a deposit review to verify the deposits reported on the Call Report/TFR for the selected quarter. The letter requests that a Designated Contact(s) be identified and directs the institution to the Guide (Interim Assessable Deposit Review Guide) for complete instructions for responding to the Deposit Review. A sample engagement letter is shown on page 17 (Exhibit A) Step 3: The Coordinator quickly identifies who will be the institution point(s) of contact (“Designated Contact”) for the review and makes certain that the Designated Contact(s) is an established user on FDICconnect and has been given EFE transaction authority within


15

FDICconnect. The Coordinator advises DCAS via email ([email protected]) of the institution’s Designated Contact(s) for the review. Step 4: Once notified of the Designated Contact(s), the FDIC establishes an EFE communication session within FDICconnect to facilitate the secure exchange of documentation with the institution. Step 5: The FDIC sends an email notice to the Designated Contact(s) advising that files containing the Deposit Recap and Average Summary are available on EFE for download by the institution to use as an inventory/documentation tool if it so wishes. Step 6: The Designated Contact(s) coordinates the preparation and transmittal of the requested documentation to the FDIC. The documentation should be assembled and returned through EFE within seven (7) business days after the electronic engagement letter is made available for download. The documentation requested in the engagement letter should be compiled from the daily systems of record control summaries routinely used each day by an institution to balance and reconcile deposit activities. A deposit review will typically occur after the Call Report/TFR under review has been filed and the assessment payment for the period associated with that Call Report/TFR has been collected; therefore, an institution’s reported deposits will have already been subjected to its internal control and verification processes. Since an institution with strong internal control and verification procedures routinely obtains and reviews the information being requested to ensure its reporting process is working as intended, meeting the seven day standard should not be a problem. In some cases DCAS may request additional documentation and clarification in support of the Deposit Review. If full documentation (both deposit amount totals and supporting system control sheets) is not submitted during a Deposit Review, an institution will be asked to correct their submission. Therefore, supporting documentation should be sufficiently detailed to avoid the need to make subsequent requests for additional information. Step 7: DCAS staff will complete the review and issue a final report to the institution’s CEO, which will describe the deficiencies, if any. The final report will identify the institution’s overall compliance with assessable deposit reporting requirements, including the timeliness of the response(s) to any documentation requests, the use of FDICconnect and the EFE, and any reporting issues. If deposit reporting deficiencies and recommendations are brought to the attention of an institution’s management and detailed in the final report, DCAS will conduct a follow-up review to ensure that the deposit reporting issues identified were resolved in a timely and appropriate manner. Follow-up reviews will generally occur four to eight quarters after the initial deposit review has been completed. When material deposit reporting deficiencies or errors are identified, an institution may be required to review additional quarters’ Call Report/TFR assessment lines to determine if similar errors occurred, and amend the assessment lines for those quarters.


16

Chapter Summary The Deposit Review evaluates an institution’s assessable deposit reporting for a particular quarter, including the accuracy of the amounts reported on the assessment lines. In general, the amounts reported on an institution’s assessment lines for the selected quarter will be compared to the deposit amounts contained on the inventory listing and supporting systems of record. If the amounts reported on the assessment lines are inaccurate, an institution may be requested to amend the Call Report/TFR under review, as well as previous Call Reports/TFRs if the error is likely to have also occurred in previous quarters. Deposit Reviews are conducted using the EFE component of FDICconnect. At the end of the review, a final report will be issued to the institution’s CEO.


17

Exhibit A – Sample Deposit Review Engagement Letter

FDIC Federal Deposit Insurance Corporation Deposit Compliance Analysis Section (Date)

Chief Executive Officer Bank Name Location

Deposit Compliance Review Engagement

The Deposit Compliance Analysis Section (“DCAS”) of the Federal Deposit Insurance Corporation (“FDIC”) has selected your institution for a compliance review to verify deposits reported on the Call Report/Thrift Financial Report, as reflected on your invoice as follows:

REPORT OF CONDITION DATA

Your institution’s first step is to send the name of the contact(s) for this review to the FDIC so that we may establish the Electronic File Exchange session to facilitate a secure exchange of the documentation. Your institution’s designated contact(s) with FDIC is expected to send supporting documentation for deposits reported on the Call Report/Thrift Financial Report, as reflected on your invoice, within seven (7) business days from the date of this engagement letter. FDIC has previously provided you with an Interim Assessable Deposit Review Guide (“the Guide”) that fully explains this review process. Refer to the Guide for further guidance and assistance in completing this request for documentation. If you do not have a copy of the Guide, you may use FDICconnect to download a new copy. Upon completion of the deposit review, FDIC will issue a final report which will describe deficiencies, if any. If you have questions about completing this Deposit Compliance Review request for supporting documentation, or if you cannot provide the documentation within the seven days, please contact [email protected] or call (972) 761-2169. Sincerely, David Wisnewski, Manager, DCAS

Assessment Period: 1st Quarter 2007 Report Date: March 31, 2007

Schedule Line Item Description Amount RC-O / DI 1 / 510 Quarter End – Total Gross Deposits 520,153,000 RC-O / DI 2 / 520 Quarter End – Total Exclusions 100,000 RC-O / DI 3 / 530 Quarter End – Total Foreign Deposits 50,000 RC-O / DI 4 / 540 Qtly Avg – Total Gross Deposits 505,590,000 RC-O / DI 5 / 550 Qtly Avg – Total Exclusions 95,000 RC-O / DI 6 / 560 Qtly Avg – Total Foreign Deposits 45,000


18

Chapter 4 – Using the Deposit Recap and Average Summary The FDIC has developed the Deposit System Control Summary Recap (“Deposit Recap”) and the Gross Total Average Deposit Reporting Summary (“Average Summary”) to aid institutions in compiling their assessable deposits, and to use as a format for Deposit Review documentation. The FDIC developed the Deposit Recap and the Average Summary with three purposes in mind: (1) to use as a tool when compiling the amounts to report on the Call Report/TFR assessment lines (2) to use as a self assessment internal control tool, and (3) to use as an inventory listing that would satisfy Deposit Review requests for documentation. An institution should decide how to integrate the Deposit Review documentation needs into its internal control procedures and automated systems. The FDIC offers the use of the Deposit Recap and Average Summary as an effective format for meeting Deposit Review documentation requirements. For an institution that elects to develop its own formats, the FDIC encourages it to develop formats that meet its unique circumstances yet fully captures the required information. The FDIC believes that having the Deposit Review information on hand every quarter will save an institution time and eliminate the need for multiple submissions to the FDIC during a Deposit Review. If full documentation (both deposit amount totals and supporting system control sheets) are not submitted during a Deposit Review, an institution will be required to correct their submission. This chapter contains step-by-step guidelines for completing the Deposit Recap and the Average Summary. An institution that elects to use the Deposit Recap and Average Summary will gain a working knowledge of how to complete these listings and generally may result in more accurate and complete assessable deposit documentation. An institution that develops its own formats in support of their assessable deposit reporting will gain a conceptual understanding of the FDIC’s expectations for Deposit Review documentation by reviewing this chapter, and can use the FDIC’s formats as a blueprint for developing their own. There is a sample of the Deposit Recap and the Average Summary at the end of this chapter: Exhibit B – Deposit Recap, Exhibit C - Average Summary. The Deposit Recap The Deposit Recap supports the reporting on Call Report Schedule RC-O items 1, 2, and 3, or TFR Schedule DI lines 510, 520, and 530. The Deposit Recap is an inventory of deposit systems that contains three parts corresponding to the three Call Report/TFR quarter-end assessment lines. Each part summarizes the documentation and detail information used to help an institution ensure that all deposits and exclusions have been accurately reported and adequately documented. Careful preparation of the Deposit Recap will ensure that complete documentation will be readily available to transmit to the FDIC during a Deposit Review. An institution that develops its own formats should ensure


19

that its formats adhere to the same basic documentation concepts. The components of the Deposit Recap are: Part I – A summary of the Deposit System Totals used to derive the amounts reported on Call Report Schedule RC-O, item 1, or TFR Schedule DI, line DI 510. Part II – A summary of the Total Allowable and Other Exclusions reported on Call Report Schedule RC-O, item 2, or TFR Schedule DI, line DI 520. Part III – A summary of the Total Foreign Deposits reported on Call Report Schedule RC-O, item 3, or TFR Schedule DI, line DI 530. The Average Summary The Average Summary supports the reporting on Call Report Schedule RC-O items 4, 5, and 6, or TFR Schedule DI lines 540, 550, and 560. The Average Summary may be used by institutions reporting daily average balances to calculate their daily average deposits and to substantiate their average calculations. The Average Summary details the daily deposit amounts that are used to compute the daily average deposits each quarter. To use this listing most effectively, an institution could complete a Deposit Recap (or similar deposit inventory listing) for each business day in the quarter, and enter those amounts on the Average Summary. The average calculation can be computed by dividing the totals for the quarter by the number of days in the quarter. (For days the institution is closed, e.g., Saturdays, Sundays, holidays or any day no transactions are posted to the general ledger, the amounts outstanding from the previous business day would be used.) This amount could then be used to substantiate the amounts on Schedule RC-O, items 4, 5, and 6 or Schedule DI, lines DI540, DI550 and DI560. Data Sources for the Deposit Recap and Average Summary Deposit “systems of record” are the foundation for assessable deposit reporting and verification. In a Deposit Review, an institution needs to identify the gross amount of all deposits and each system of record supporting these deposits. In general, a deposit “system of record” is any system that an institution uses to track, control, and handle inquiries from depositors about their specific accounts and to substantiate the corresponding amounts in those accounts. These systems typically produce the information reported as deposits on the Call Report/TFR assessment lines. The control total summary page for each deposit system of record is the primary source of data for substantiating the amounts reported for a Deposit Review. As discussed in some detail in Chapter 1, the FDI Act definition of deposit includes a broad range of “funds held” by an institution. Some funds held by an institution are intuitively deposits


20

and their corresponding system of record is relatively easy to identify. For instance, funds held in checking accounts are universally recognized as deposits, and their system of record is the DDA (Demand Deposit Account) system. On the other hand, some funds held by an institution are not as universally recognized as deposits. For instance, mortgage escrow funds meet the definition of a deposit, but may be overlooked because their system of record is a loan system. Some types of deposits are not handled on automated processing systems. For example, the system of record for cashier’s checks outstanding might be a spreadsheet that tracks when a cashier’s check is issued and when it is cleared. When compiling the information for the Deposit Recap, an institution should make sure that it has identified all systems that process or record items that meet the FDI Act definition of a deposit (Chapter 1 has a list of commonly overlooked deposits). Some institutions may find it beneficial to involve operations personnel in the assessment deposit reporting process since they are familiar with all the systems of the institution. In addition, external deposit servicers who are familiar with deposit systems may also be beneficial sources of information. Guidelines for Completing the Deposit Recap Part I – Deposit System Totals Before Exclusions The first step in preparing the Deposit Recap is to identify all of the deposit systems of record (both the traditional deposit systems and other sources of funds as discussed above) and gather all the information needed to complete the Deposit Recap. Each line item in Part I contains information related to each specific system of record (manual or automated) identified by an institution as containing deposits. For most types of deposits, the system of record would be the control total summary page that usually contains most of the information that will be needed for compiling and documenting the reported gross deposit amounts (Call Report Schedule RC-O items 1 & 4, or TFR lines DI 510 & 540.) Chart 1 illustrates Part I of the Deposit Recap. Detailed guidelines for completing Part I are listed below the chart.


21

Chart 1 – Deposit Recap Part I

Deposit System Control Summary Recap

Institution: 1111 - ABC Bank Recap Date: 3/31/2008

Quarter Begin: 1/1/2008 Call Rpt/Quarter End: 3/31/2008 Day: 91 of 91 Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: Box # 1 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #

Deposit system total (gross) - Identified by

Deposit System of Record (Control Sheets)

# of Deposit Accounts

Accrued Interest

Overdrafts/ Negative

Bal. Total on System Totals 0 $0.00 $0.00 $0.00

Box # 1– Enter the amount reported on Call Report Schedule RC-O item 1, or TFR line DI510. Column 1 - Assign a number sequentially to each deposit system listed. The same system number will be used for reference purposes to identify the systems that include exclusions reported in Part II, for example, Systems #1, #2, #3, etc. Insert rows for additional systems as needed. Column 2 - List the title that appears on the system of record report that contains the deposit amounts being reported, for example, the DDA system. Column 3 - List the amount that represents the number of individual depositor accounts recorded in the listed system of record. This information is generally available on the control total summary page for automated deposit systems. However, this total may include single accounts that represent the aggregation of several individual depositors into one account. An example would be a DDA account for the trust department to record trust cash. This account may be treated as one account in the system control total, but does, in fact, represent balances for several individual depositors (trust customers with uninvested cash). The amount listed should be adjusted to reflect such situations. Providing the number of accounts as part of the validation process ensures that all deposit systems have been properly identified, summarized, and included in the reported amounts. Column 4 - List the amount of interest on deposits accrued, but not yet paid or credited to a deposit account for each corresponding system that is listed on the Deposit Recap. For instance,


22

accrued interest derived from the certificate of deposit system should be available on the control total summary page of an automated system of record. Column 5 - List the amount of overdrawn accounts or other negative amounts included that reduced the summary balance listed in column 6. Pay particular attention to negative amounts in any aggregate account included in the system of record. If there is another system (sub-system) associated with the summary balance (such as a trust cash system), an institution should include that system’s overdrafts on this line as well. Individual balances included on automated systems can be negative as well as positive. For instance, an overdrawn checking account could be recorded as a negative balance on the DDA system. (Overdrafts are classified as loans on the Call Report/ TFR, instead of negative deposits.) Since summary balances on control total pages of automated systems are typically reported on a net basis, the overdrawn balances have in effect reduced the positive balances on the summary report. Therefore, in order to track the correct deposit balances on a gross basis these amounts are listed separately in column 5. Another example of an account that should be listed in column 5 is advances on mortgage escrow accounts since these are negative balance accounts that have reduced the summary balance amount. Column 6 - List the deposit ending balance amount from each system of record. Automated deposit systems have a control total summary page which usually includes the totals that correspond to the summary balances at the end of the day. This is the amount to include in column 6. Part II – Total Allowable Exclusions and Other Exclusions Chapter 2 contains a detailed discussion of Allowable Exclusions and Other Exclusions. Each line item in Part II contains information identifying exclusions used in the assessment calculation. Each amount listed must have been included in one of the systems of record identified in Part I. The FDI Act Section 7(b) (4) states in part, “Each insured depository institution shall maintain all records that the Corporation may require for verifying the correctness of any assessment on the insured depository institution.” Therefore, records should be maintained to confirm these amounts are included in one of the systems of record identified in Part I, and to substantiate that these amounts are valid exclusions. List in this part the amounts that meet the criteria of an “Allowable Exclusion” as defined in the FDI Act and the FDIC’s Rules and Regulations. There are seven specific types of Allowable Exclusions (refer to Chapter 2 for details): • Foreign Deposits • Reciprocal Balances • Drafts Drawn on other Institutions • Pass-Through Reserve Balances

• Depository Institution Investment Contracts • Hypothecated Deposits • Unposted Items


23

Additionally, there may be “Other Exclusion” amounts included in Part I that would be appropriately included in Part II. Non-deposit amounts included in Part I must be separately identified to ensure they are handled appropriately in the quarterly reporting process. An example of this would be home equity lines of credit amounts that are sometimes recorded on DDA systems. Since customers use checks to access their home equity line of credit, the DDA system might be used to track the loan balances. In such cases it would be appropriate to list in Part II the amount of home equity lines of credit amounts that increased the control total amounts of the DDA system listed in Part I. Allowable Exclusions reported in Part II should be categorized by the system from which they were derived, using the same system numbers listed in Part I. Other Exclusions can be combined and reported as one amount. Please note that eligible foreign deposits are reported as Allowable Exclusions. See the Appendix for details. Chart 2 illustrates Part II of the Deposit Recap. Detailed guidelines for completing Part II are listed below the chart.

Chart 2 – Deposit Recap Part II

Part II: Total Allowable and Other Exclusions (Including Foreign Deposits) - RC-O Item 2 or DI520: Box # 2 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #

Allowable and Other exclusions (including

foreign deposits) # of Deposit

Accounts Accrued Interest



Box # 2- Enter the amount reported on Call Report Schedule RC-O item 2, or TFR line DI520. Column 1- Identify the system number recorded in Part I from which the exclusion(s) is derived. Column 2- Identify the name of the system recorded in Part I from which the exclusion(s) is derived. Column 3- List the number of accounts associated with the exclusion(s) amount. Column 4- List the amount of accrued interest associated with the exclusion(s) that was included in Column 4 of Part I. Column 5- List the amount of overdrawn or other negative amounts associated with the exclusion(s) that was included in Column 5 of Part I. Column 6- List the total amount of the exclusion(s).


24

Part III-Total Foreign Deposits Chapter 2 contains a detailed discussion of Foreign Deposit Reporting. List the information applicable to Foreign Deposits (included in gross systems totals) that were included in Part I and Part II. This part is not applicable to institutions filing the FFIEC 041 Call Report Form. Chart 3 illustrates Part III of the Deposit Recap. Detailed guidelines for completing Part III are listed below the chart.

Chart 3 - Deposit Recap Part III

Part III: Total foreign deposits (included in gross system totals and in total Allowable Exclusions) - RC-O Item 3 or DI530: Box # 3 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System # Foreign Deposits


Accrued Interest



Box # 3 – Enter the amount reported on Call Report Schedule RC-O item 3, or TFR Schedule DI line 530. Column 1 - Identify the system number recorded in Part I in which the Foreign Deposits were included.

Column 2 - Identify the name of the system recorded in Part I in which the Foreign Deposits were included.

Column 3 - List the number of foreign accounts.

Column 4 - List the amount of accrued interest associated with the foreign accounts that were included in Column 4 of Part I. Column 5 - List the amount of overdrawn or other negative foreign accounts.

Column 6 -List the total amount of Foreign Deposits.


25

Completing the Average Summary For an institution that reports average deposits, the Average Summary summarizes the information provided on the Deposit Recap for each reporting day of the quarter and can be used to validate the calculation of the gross total daily average deposits. Chart 4 illustrates an abbreviated Average Summary (see Exhibit B for the full Average Summary). Detailed guidelines for completing the Average Summary are listed below the chart.

Chart 4 - Average Summary Line

Gross Total Average Deposit Reporting Summary

Institution: 11111 - ABC Bank Quarter Begin: 1/1/2008

Call Rpt/Quarter End: 3/31/2008

Col 1 Col 2 Col 3 Col 4 Col 5 Col 6 Col 7 Col 8

Day Date

# of Deposit

Accounts - Part I

Total Deposit

Liabilities Before

Exclusions (Gross) -

Part I

# of Deposit

Accounts - Part II

Total Allowable Exclusions (Including

Foreign Deposits) -

Part II

# of Deposit

Accounts - Part III

Total Foreign Deposits (Included

In Allowable

Exclusions) - Part III

1 Tuesday, January 01, 2008 2 Wednesday, January 02, 2008 3 Thursday, January 03, 2008

89 Saturday, March 29, 2008 90 Sunday, March 30, 2008 91 Monday, March 31, 2008

Daily Average

Column 1- It could be helpful to list the sequential day of the quarter (day 1,2,3, etc.) Column 2- List the day/date of the daily Deposit Recap applicable to this line. (Since the rows for non-business days (Saturdays, Sundays, holidays, etc.) are populated with the previous day’s deposit amounts, it could be helpful to include the day of the week or note holidays in this column.)

Column 3- List the total in Part I, Column 3 (# of Deposit Accounts) of the applicable Deposit Recap.


26

Column 4- List the sum of the total lines for Part I, Columns 4, 5 and 6 of the applicable Deposit Recap.

Column 5- List the total in Part II, Column 3 (# of Deposit Accounts) of the applicable Deposit Recap.

Column 6- List the sum of the total lines for Part II, Columns 4, 5 and 6 of the applicable Deposit Recap. Column 7- List the total in Part III, Column 3 (# of Deposit Accounts) of the applicable Deposit Recap. Column 8- List the sum of the total lines for Part III, Columns 4, 5 and 6 of the applicable Deposit Recap. For days the institution is closed for business, e.g., Saturdays, Sundays, holidays or any day where no transactions are posted to the general ledger, the amount from the previous business day is used. After all days of the quarter are included on the spreadsheet, separately total Columns 4, 6, and 8 and divide that number by the number of days in the quarter. This will be the average used to validate the amounts recorded on Schedule RC-O, items 4 (Column 4), 5 (Column 6), and 6 (Column 8) or Schedule DI, lines 540, 550 and 560. The Appendix contains helpful examples of how to prepare the Deposit Recap and Average Summary. The Sample Documentation Package Appendix I uses a hypothetical institution to further illustrate how to complete the listings using mock-up systems of record. The package is not all inclusive, but merely a sample of some types of deposits and systems institutions may have. The package demonstrates how to go from a system of record amount to the amount reported on the assessment lines using typical situations that an institution may encounter when preparing the listing, and offers detailed guidance on how to list such information on each Part. Chapter Summary The Deposit Recap and the Average Summary were developed for institutions to use in conjunction with their deposit reporting internal control process, or to use as a model for developing their own formats. For institutions that elect to use the Deposit Recap and/or Average Summary, the step-by-step instructions for their use should be helpful integrating these formats into their comprehensive deposit internal control program.


27

Exhibit B: Deposit System Control Summary Recap (“Deposit Recap”)



Quarter Begin: 1/1/2008 Call Rpt/Quarter End: 3/31/2008 Day: 91 of 91 Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: Box # 1 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #

Deposit system total (gross) - Identified by

Deposit System of Record (Control Sheets)


Accrued Interest



Part II: Total Allowable and Other Exclusions (Including Foreign Deposits) - RC-O Item 2 or DI520: Box # 2 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #

Allowable and Other exclusions (including

foreign deposits) # of Deposit




Part III: Total foreign deposits (included in gross system totals and in total Allowable Exclusions) - RC-O Item 3 or DI530: Box # 3 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6



Accrued Interest




28

Exhibit C: Gross Total Average Deposit Reporting Summary (“Average Summary”)

Gross Total Average Deposit Reporting Summary

Institution: 11111 - ABC Bank Quarter Begin: 1/1/2008

Call Rpt/Quarter End: 3/31/2008

Col 1 Col 2 Col 3 Col 4 Col 5 Col 6 Col 7 Col 8

Day Date

# of Deposit Accounts -

Part I

Total Deposit Liabilities

Before Exclusions

(Gross) - Part I

# of Deposit

Accounts - Part II


Foreign Deposits) -

Part II

# of Deposit

Accounts - Part III

Total Foreign Deposits

(Included In Allowable


1 Tuesday, January 01, 2008

2 Wednesday, January 02, 2008

3 Thursday, January 03, 2008

89 Saturday, March 29, 2008 90 Sunday, March 30, 2008 91 Monday, March 31, 2008

Daily Average


29

Chapter 5 – FDICconnect and Examination File Exchange (EFE) FDICconnect, established in response to legislation requiring agencies to offer on-line alternatives to paper-based processes, is the secure Internet channel for FDIC-insured institutions to conduct business and exchange information with the FDIC. (Since March 2005, institutions have been downloading their FDIC quarterly certified statement invoices through FDICconnect.) Deposit Review activities are conducted through FDICconnect and its EFE component, including transmittal of the engagement letter, exchange of documentation, and transmittal of the final report. Therefore, it is important for an institution to incorporate FDICconnect coverage in its internal control procedures. This chapter explains the role FDICconnect plays in the Deposit Review process. EFE (Examination File Exchange) is a feature of FDICconnect that establishes secure electronic communication between an insured institution and the FDIC, and is used for the transfer of files and messages related to Deposit Reviews through an EFE “session.” The session itself is opened by the FDIC and creates a secure and confidential conduit with an institution being reviewed. Within the session, files and information are exchanged in support of the Deposit Review. All Deposit Review activities (including communication, requests for information, and commitments from both the FDIC and an institution being reviewed) are documented in the “Session Notes” feature of the EFE. This will ensure confidentiality and make the status and documentation available to all session participants. An institution’s Chief Executive Officer (CEO) or designee is expected to delegate FDICconnect responsibilities to institution personnel and put into place processes that ensure the capability to access and retrieve correspondence and/or files sent via FDICconnect. An institution should have FDICconnect coverage at all times. The FDICconnect Coordinator is the person notified when a Deposit Review is scheduled. The standard for transmitting the requested documentation to the FDIC is seven days from when the engagement letter was made available on FDICconnect. Therefore, it is imperative that an institution has an active FDICconnect Coordinator and that a succession plan exists to replace the Coordinator and any other of the institution’s users in the event of staffing and/or responsibility changes. Gaining Access and Using FDICconnect and EFE The FDIC recommends that the FDICconnect Coordinator, as well as the Deposit Review Designated Contact(s), have access to EFE. To access EFE, an institution must have at least one FDICconnect Coordinator. The Coordinator has the ability to approve other personnel as “users” of each individual FDICconnect function. Most FDIC insured institutions have already completed the registration process and designated a FDICconnect Coordinator. The registration process is explained in detail on the FDICconnect website at https://www2.FDICconnect.gov/). A comprehensive EFE Help link is available and provides simple instructions on how to use EFE and exchange files with FDIC personnel. Once logged in to FDICconnect, the first step is to expand the Examination Related Transmissions menu and launch EFE. The Help link is at the top, center of each page (“Help”).


30

Once an institution has been selected for a Deposit Review, the FDIC will formally notify the institution’s FDICconnect Coordinator via an e-mail message that the engagement letter is available for download through FDICconnect. The engagement letter, addressed to the institution’s CEO, will explain the purpose of the review and refers the institution to the Guide for further Deposit Review instructions. The Coordinator is responsible for advising institution personnel of the review and for distributing the engagement letter as deemed appropriate. The FDICconnect Coordinator is responsible for facilitating and monitoring the progress of the Deposit Review process and as such the FDIC will include the Coordinator in the sessions. The Coordinator should promptly identify to the FDIC the institution’s contact(s) for the Deposit Review (Designated Contact). The Coordinator should ensure that the Designated Contact(s) is a registered FDICconnect user and should “assign” the EFE transaction privileges to the Designated Contact(s). If the Designated Contact(s) is not yet a FDICconnect user, this person must complete the registration process through the FDICconnect website. Use of EFE during a Deposit Review An EFE session is the primary forum for communicating and transmitting information during a Deposit Review. EFE session- EFE sessions are the forums to facilitate communication and exchange of files during a Deposit Review. Once an institution’s Deposit Review Designated Contact(s) has been established, the FDIC will initiate an EFE “session” with the Designated Contact(s) and the FDICconnect Coordinator. The institution’s Designated Contact(s) will receive an email (see Chart 5 below for a sample email) advising that an EFE session has been established by the FDIC and instructing the Designated Contact(s) to log-in to EFE to access the session. EFE generates e-mail notifications to all members included in the session each time a party on either side (insured institution/FDIC) submits information to the session. The e-mail informs the other side that something new has been transmitted.

Chart 5 – EFE Notification Email From: FDICconnect [mailto:[email protected]] Sent: Friday, November 02, 2007 3:44 PM To: [email protected] Subject: An Exam File Exchange Session Has Been Opened - IA, MIDDLETOWN, MIDDLETOWN STATE BANK Good day! The FDIC has initiated a file exchange session with you from FDICconnect. FDIC Contact: John Doe Contact Information: 999-999-9999 Exam Type: Assessment Session Description: Assessable Deposit Review Expiration Date: 08/31/2008 Please log-in to http://www.fdicconnect.gov/ to access the session.

Once the EFE session has been opened, instructions will be available for the Designated Contact to follow. For instance, the first EFE session will contain files designed to aid


31

institutions in the collection and inventory of all deposit accounts by their respective system of record, such as the Deposit Recap and the Average Summary. During EFE sessions, the Designated Contact will be able to download files from the FDIC and upload documentation files to the FDIC. EFE sessions will remain open through the completion of the Deposit Review and the issuance of the final report. The files and correspondence exchanged will remain on-line and available while the EFE session is open. Once the session is either closed by the FDIC or is allowed to expire, the session and its attached files will no longer be available to the institution. It is an institution’s responsibility to retain backup files of information sent to the FDIC if so desired. File Formats Most file formats (Word, Excel, etc.) can be exchanged on EFE. The Deposit Review requires that an institution maintains supporting documentation of the system of record deposit totals used to compile the amounts reported on the Call Report/TFR assessment lines (see Chapter 3). This documentation should be in an approved electronic format that is readable and that can be readily transmitted to the FDIC using EFE. EFE is flexible, and different file formats can be exchanged between the FDIC and insured institutions. However, to expedite the review process, it is requested that whenever possible files or documents exchanged be in PDF, DOC, XLS or CSV. If unable to provide any of these preferred formats, any of the following data types may be transmitted through EFE.

Chart 6 – File Formats that may be exchanged in EFE

Help with EFE EFE and FDICconnect assistance is available online through the FDICconnect website (https://www2.FDICconnect.gov/) by email ([email protected]) or by telephone (1-877-275-3342). For problems with FDICconnect or EFE, institution personnel should first contact the institution's FDICconnect Coordinator. If additional guidance is needed, please contact the

ANS (Text with layout) BMP, DIB, RLE (Windows Bitmap) ASC (MS DOC with text layout) BMP, DIB, RLE (Windows Bitmap) CSV (Comma Delimited File) DAT (data files) DIF (Data Inter change format) DBF (DBase file) DOC (Word) HTML , HTM (web page) GIF (Graphics Interchange format) MCW (MS word for Mackintosh) JPG, JPEG, JPE, JFIF PDF (Printer Definition File) MDB (Access Database) PRN (Formatted text space delimited) PPT (Power Point) PUB (MS Publisher file) PRN (Printer Text File) WPD (Word Perfect) RTF (Rich Text Format) XLS (Excel) (XLW Excel 4.0 files) TXT (regular txt file) ZIP (ZIP files) WPS (Works 2000 & older MS Word) TIF or TIFF (Tag Image File Format) XML (XML Data string)


32

FDICconnect Help Desk at [email protected] or at 1-877-275-3342. The telephone menu selection is 1-1-5. Since each institution is required to use FDICConnect for downloading assessment invoices and other FDIC business purposes, the FDIC believes that institutions will be able to conduct their Deposit Reviews electronically. Chapter Summary FDICconnect and EFE are the primary means for the FDIC and insured institutions to communicate and share documentation during a Deposit Review. In order to successfully participate in a Deposit Review, an institution needs to have at least one active FDICconnect Coordinator, and at least one active EFE user. Since an institution may experience staff turnover, a component of an institutions internal control procedures should be a FDICconnect succession plan to ensure ample coverage and a prompt response in the event of a Deposit Review.


33

Appendix: Sample Documentation Package Introduction This section of the Guide is a hypothetical sample documentation package designed to help an institution gain insights into how to respond timely and accurately to a FDIC request for a Deposit Review. The Deposit Recap (Deposit System Control Summary Recap) and Average Summary (Gross Total Average Deposit Reporting Summary) formats (see Chapter 4) are being used for illustration purposes. This sample documentation package illustrates how an institution might compile and summarize the deposit information from their deposit systems of record. (Depositors’ names can be redacted from documentation transmitted to the FDIC.) This package also shows how to document and summarize deposits when verifying average daily balance reporting. The sample documentation package does not contain a comprehensive listing of all types of deposits or exclusions an institution must report; it contains a variety of types of deposits and systems of record selected for illustration purposes. The hypothetical institution in this example, ABC Bank, reports both quarter-end and daily average balances that includes both foreign and domestic deposits. As a result, each quarter it would be reporting on either Schedule RC-O, Line 1 through 6 or Schedule DI, Line DI510 through DI560. In this sample documentation package, six main (“master”) systems are used to illustrate the different types of systems of record, and to illustrate how to identify their associated deposits to be reported on the Call Report/TFR assessment lines. The six main systems are: • Demand Deposit Account (DDA) System – (System 1) – Contains transactional or

checking accounts processed on an automated deposit system. • Savings Deposit System – (System 2) – Contains traditional kinds of domestic and foreign

accounts with no fixed terms processed on an automated deposit system. • Certificates of Deposit (CDs) System – (System 3) – Contains traditional kinds of fixed

term time deposits processed on an automated deposit system. • Brokered Certificates of Deposit System – (System 4) – Contains traditional kinds of fixed

term time deposits, purchased through a broker, processed on a manual system. • Mortgage Escrows System – (System 5) – Contains domestic deposits processed on an

automated non-deposit system. • Security Deposits – (System 6) – Contains deposits on a manual spreadsheet-type system. This example illustrates deposits that are contained in (1) automated deposit processing systems (Demand Deposit Accounts, Savings Deposits, Time Deposits) (2) a manual deposit processing system (Brokered Certificates of Deposits) (3) an automated non-deposit processing system (Mortgage Escrows) and (4) a manual spreadsheet-type system (Security Deposits) . (This institution has separate control totals for Savings and Time Deposits where some other institutions might have savings and certificates combined into one control sheet.)


34

Master Controls – Sub-controls For this sample documentation package, the control summary page for the system of record of each system, (deposit /non-deposit, automated/manual), will be referred to as the “master control” for the associated system of record. Thus there are six master controls corresponding to these six systems that contain ABC Bank’s deposits. In addition, there are “sub-controls” which are systems of record within each master control. For this example, there are two types of sub-controls: an embedded sub-control and an aggregation account sub-control. Embedded sub-controls are typically non-deposit product types embedded within a deposit system. For this example, the system of record for credit line accounts is a sub-control for the loan product type which is processed and accounted for within the master control DDA system (sub-system 1.A.). The sub-control documentation is typically the “activity recap” report for a specific product type (which summarizes the transactions for a given product type for that day). See Illustration 1.

Illustration 1 – Master Control – Embedded Sub-control MASTER CONTROL DDA System SUB CONTROL Checking Accounts Credit Line Activity Recap Credit Line Accounts

Aggregation account sub-controls are accounts within a deposit system that represent the aggregation of several individual depositors that are contained in one account such as brokered deposits, cashier checks outstanding, stored value accounts, and other like arrangements. In this example the aggregation account sub-control involves ABC Bank’s trust customers’ uninvested cash which is in one account processed on the DDA system. The sub-control documentation for that account is the Trust Department Daily Trial Balance. See Illustration 2. Another kind of sub-control applies to an account or accounts within one deposit system where a deposit amount is considered an allowable exclusion. The sub-control documentation in this example is the Reciprocal Balance Worksheet (sub-system 1.C.)

Illustration 2 – Master Control – Aggregation Account Sub-control MASTER CONTROL DDA System SUB CONTROL Customer Checking Accounts Trust Cash Trial Balance Trust Dept. Checking Account


35

For this sample documentation package, there is an example of a master control with two sub-controls (DDA – credit lines and uninvested trust cash), one sub-control (Savings- Foreign Deposits), and no sub-controls (Time Deposits, Security Deposits & Mortgage Escrows). The institution’s documentation for master controls and sub-controls needs to properly identify, segregate, and list the component amounts that were included in the institution’s quarterly Call Report/TFR assessment lines being reviewed by the FDIC. These mock-up system reports are presented at the end of each system (1-6) write-up. In addition, the deposit amount included in a master control sheet might include an amount that qualifies as an exclusion from assessable deposits. In this sample documentation there is an exclusion amount for reciprocal balances where the institution has both a “due to” and a “due from” relationship with another depository institution. The sample documentation package includes a fully completed Deposit Recap (page 37) and Average Summary (pages 70-72). Both of these types of listings are needed when an institution is reporting on a daily average deposits basis. In addition to these completed sample listings, this section provides a description of how each field in both listings was determined and includes observations about things to consider when assembling the documentation package. It is important to remember that an integral part of each Deposit Review is the timeliness of the institution’s response to the FDIC’s request for information. The ability to quickly and accurately prepare the documentation package is an indication of the reliability of the information presented. It is assumed that the institution’s quarterly reporting is always prepared on a consistent basis and is fully supported by appropriate regularly scheduled balancing procedures inherent in a well-run organization. As such, each FDIC Deposit Review final report will include comments and recommendations about the institution’s timeliness in providing the supporting documentation package. Quarterly Report of Deposits Being Reviewed The example begins with demonstrating the amounts reported by the hypothetical institution on the quarterly Call Report/TFR assessment lines for the period being reviewed for both the quarter-end and daily average. These amounts are entered in the “box” at the top of Part I, Part II, and Part III on the Deposit Recap as applicable. For this hypothetical example the institution reported the following amounts on Call Report Schedule RC-O or TFR Schedule DI for the March 31, 2008 report date.


36

ABC Bank REPORT OF CONDITION DATA

Assessment Period: 1st Quarter XXXX Report Date: March 31, XXXX

Schedule Line Item Description Amount RC-O/DI 1/510 Quarter End – Total Gross Deposits 1,017,576,000 RC-O/DI 2/520 Quarter End – Total Exclusions 20,565,000 RC-O/DI 3/530 Quarter End – Total Foreign Deposits 5,003,000 RC-O/DI 4/540 Qtly Avg – Total Gross Deposits 1,016,186,000 RC-O/DI 5/550 Qtly Avg – Total Exclusions 20,116,000 RC-O/DI 6/560 Qtly Avg – Total Foreign Deposits 4,913,000

Completed Documentation Package

The completed hypothetical documentation package will consist of a finished Deposit Recap (Exhibit 1) which identifies all the systems of records that contain deposits along with the supporting Control Total Summary pages from the applicable system of record. Also included is a completed Average Summary spreadsheet listing the deposit balances for each business day for the quarter being reviewed (Exhibit 11).


37

Exhibit-1 Deposit System Control Summary Recap (“Deposit Recap”)



Quarter Begin: 1/1/2008 Call Rpt/Quarter End: 3/31/2008 Day: 91 of 91 Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: $1,017,576,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #

Deposit system total (gross) - Identified by Deposit System of

Record (Control Sheets)

# of Deposit



Bal. Total on System System 1 Demand Deposits Control Summary Bank Total 7,010 $26,507.00 $1,087,375.00 $214,251,590.00

System 2 Savings Deposits Control Summary Bank Totals 4,015 $263,242.93 $0.00 $292,413,283.00

System 3 Time Deposits Control Summary Bank Totals 3,252 $1,984,593.00 $0.00 $490,205,801.75

System 4 Brokered Certificates of Deposits 165 $99,615.93 $0.00 $16,000,000.00

System 5 Mortgage Loan Trial Balance 388 $16,969.00 $269,177.00 $917,667.00

System 6 Security Deposits Account Balance 10 $0.00 $0.00 $40,000.00

Totals 14,840 $2,390,927.86 $1,356,552.00 $1,013,828,341.75

Part II: Total Allowable and Other Exclusions (Including Foreign Deposits) - RC-O

Item 2 or DI520: $20,565,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #

Allowable and Other exclusions (including foreign deposits)

# of Deposit



Bal. Total on System System 1 Demand Deposits Control Summary Bank Total 0 $0.00 $0.00 $52,000.00

System 2 Savings Deposits Control Summary Bank Totals 200 $3,000.00 $0.00 $5,000,000.00

Other Exclusions 440 $0.00 $0.00 $15,510,018.89

Totals 640 $3,000.00 $0.00 $20,562,018.89

Part III: Total foreign deposits (included in gross system totals and in total Allowable

Exclusions) - RC-O Item 3 or DI530: $5,003,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6


# of Deposit



Bal. Total on System System 2 Savings Deposits Control Summary Bank Totals 200 $3,000.00 $0.00 $5,000,000.00

Totals 200 $3,000.00 $0.00 $5,000,000.00


38

System 1 – Demand Deposit Account (DDA) System

Description of System 1 The first example describes a typical DDA system, which is the first entry on Part I of the Deposit Recap (Exhibit 1, page 37). Since checking deposits, NOW accounts and money market accounts have similar attributes, they are usually tracked in one deposit system. In some cases institutions may use a single deposit account within this automated system to manage what in effect are a number of individual depositor amounts under a sub-control for that specific activity (see Illustration 2, page 34, master control-aggregation account sub-control). In addition, DDA systems may possess features that permit their use for tracking products that are not actually customer deposits (see Illustration 1, page 34, master control-embedded sub-control). In order to identify and categorize any component(s) which require special handling, it is necessary to carefully review the system reports used under either of these methods. It is essential to make sure that every deposit account is clearly identified and the supporting documentation is provided. The system control summary provided by the institution should fully support the reported amounts required to validate the accuracy of the quarterly deposits for the period under the Deposit Review. To demonstrate how these alternate methods are to be handled when responding to a FDIC initiated Deposit Review, the System 1 example includes three elements that highlight a non-deposit element, a sub-account element, and an allowable exclusion element. The System 1 example uses Credit Line Accounts (loan product type) to illustrate a non-deposit element where the number and balance of accounts are included in the demand deposit system control summary totals (embedded sub-control). Also, the System 1 example illustrates proper documentation for an aggregation account element included in the DDA system control summary (Trust Cash). Additional types of deposits that might be embedded in System 1 could be outstanding checks, unremitted payments to participants, etc. In addition, the System 1 example illustrates proper documentation for an allowable exclusion from gross deposits (Reciprocal Balances). Each amount listed as an exclusion in Part II – Total Allowable Exclusions (including Foreign Deposits) and Other Exclusions must also be included in one of the systems of record identified in Part I – Deposit System Totals Before Exclusions. If the institution has adjusted (reduced) the system total amount reported in Part I for the amount of non-deposits, there can be no exclusion reported in Part II (in other words, if an amount is not included in Part I, it cannot be included in Part II). Supporting Documentation: Supporting documentation required to complete the System 1 example includes the DDA system master control summary and each of the three sub-control reports described above that are needed to complete all three parts of the Deposit Recap for Example 1. System 1 - Master Control: “Demand Deposit Control Summary Bank Totals”. This depicts a typical control total summary page that reports the number of DDA accounts, overdrafts,


39

accrued interest and total deposit ending balance for the processing date (refer to Exhibit 2 page 44).

System 1A - Sub-Control: “Credit Line Accounts Type 83 Activity Recap.” This depicts a typical activity Recap report for product Type 83 – Credit Line Accounts. The report contains sufficient information to identify the number of Credit Line Accounts and the total Credit Line ending balance for the processing date (refer to Exhibit 3 page 45). System 1B - Sub-Control: “Trust Department Daily Trial Balance.” This depicts a typical trial balance showing each trust customer’s uninvested cash balances and those accounts that are negative along with the control summary information, including the number of accounts and the trust account ending balance for the processing date (Exhibit 4 page 46). System 1C - Sub-Control: “Reciprocal Balance Worksheet.” This depicts a typical worksheet showing the exclusion of deposit amounts when an institution has a “due to” and “due from” balance with another financial institution (Exhibit 5 page 47).

Completing System 1 - Part I of the Deposit Recap (Exhibit 1) The information from the Demand Deposit Control Summary Bank Totals and Trust Department Daily Trial Balance is transferred to Part I of the Deposit Recap as indicated below. Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: $1,017,576,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #



# of Deposit



Bal. Total on System System 1 Demand Deposits Control Summary Bank Total 7,010 $26,507.00 $1,087,375.00 $214,251,590.00

Below are detailed explanations for completing the information listed for System 1 in Part I of the Recap: Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case, enter “System 1” which pertains to the first system listed in Part I. Column 2: Enter the actual title that appears on the system of record that contains the master control amounts being reported and the number of sub-control accounts. In this case enter “Demand Deposit Control Summary Bank Totals.” Column 3: Enter the number of individual depositor accounts contained in the listed system of record being reported. In this case enter “7,010”. In this example, substitute the one Trust Department DDA account included in the total number of accounts in the Demand Deposit Control Summary Bank Totals with the ten (10) Trust Department accounts. [7,001-1+10 = 7,010]


40

Special Note: The number of accounts reported in Column 3 must be adjusted when the number of individual depositor accounts recorded in the DDA system includes a single account that represents the aggregation of more than one depositor into one account (aggregation account, sub-control). In this example, the institution maintains a single demand deposit account to process trust cash for multiple trust customers and the net balance for this single account is included in the overall system total and counted as one account. The actual number of deposit accounts for the DDA system should be adjusted upward to include the total number of deposit accounts found in the trust cash trial balance. Substitute the one Trust Department DDA account included in the total number of accounts in the Demand Deposit Control Summary Bank Totals (System 1) with the ten (10) Trust Department accounts (System 1B). Column 4: Enter the amount of interest accrued and unpaid for the system of record that contains the amounts being reported. In this case enter “$26,507.00” ITEM 3 from the System 1 sample report (Exhibit 2 page 44). Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in column 6. In this case enter “$1,087,375.00”. This is the total of $952,375.00 (Exhibit 2, page 44, ITEM 1 ) plus the $135,000.00 (Exhibit 4, page 46, ITEM 1 ) is the amount of overdrawn or negative balance accounts for the deposit systems being reported. In this example, the Trust department has 10 customers with cash accounts and 3 of these 10 customer accounts actually reflect an overdrawn trust cash balance that was included in the net control summary total. The total for all overdrawn trust cash accounts is $135,000.00. (If the trust cash DDA account has a net overdraft balance, replace that overdraft amount with the gross overdrawn balances of the individual trust customers). Special Note: The ending balance as shown on the DDA System Control Report is net of individual accounts in an overdraft status. Section 7(a)(4) of the FDI Act provides that each insured institution shall report the total amount of deposits “ without any deduction for indebtedness of depositors. . . .” The overdraft amounts in the individual DDA accounts are to be listed separately in Column 5 on the Deposit Recap to ensure reporting of deposits on a gross basis. In this example, since the institution utilizes a demand deposit account for the processing of trust cash, the correct amount of overdrafts to report separately must be the amount (balance) of overdrafts reflected in System 1 (Exhibit 2, page 44, ITEM 1 ) and the amount of overdrafts from the trust cash account on System 1.B (Exhibit 4, page 46. ITEM I ).

Column 6: Enter the total deposit amount actually shown on the system of record being reported. In this case enter “$214,251,590.00” (Exhibit 2, page 44, ITEM 4 ).


41

Completing System 1 - Part II of the Deposit Recap (Exhibit 1) The information from the Reciprocal Balance Worksheet and Credit Line Accounts Type 83 Activity Recap is transferred to Part II of the Deposit Recap as indicated below.

Part II: Total Allowable and Other Exclusions (Including Foreign Deposits) - RC-O Item 2 or DI520: $20,565,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #


# of Deposit



Bal. Total on System System 1 Demand Deposits Control Summary Bank Total 0 $0.00 $0.00 $52,000.00

Other Exclusions 440 $0.00 $0.00 $15,510,018.89 Since System 1 includes an Allowable Exclusion (Reciprocal Balances) and an amount for Other Exclusions, entries are made in both sections of Part II for System 1. Special Note: Reciprocal Balances arise when two depository institutions maintain deposit accounts with each other, i.e. when a reporting bank has both a “due from” and a “due to” balance with another depository institution. Reciprocal Balances between the reporting bank and other depository institutions may be reported on a net basis when a right of setoff exists, resulting in an Allowable Exclusion.

Below are detailed explanations for completing the information listed for System 1 in Part II of the Deposit Recap as Allowable Exclusions:

Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case enter “System 1” which pertains to System 1 listed in Part I. Column 2: Enter the actual title that appears on the master control system of record that contains the amounts being excluded. In this case enter “Demand Deposit Control Summary Bank Totals.” Column 3: Enter the number of individual depositor accounts contained on the sub-control system of record being excluded. Since there are no accounts to be excluded in this example enter “0.” Column 4: Enter the amount of interest accrued and unpaid contained on the sub-control system of record being excluded. Since there is no interest accrued and unpaid amount for the Reciprocal Balance Worksheet System 1.C enter “$0.00.” Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in Column 6 associated with the amount being excluded. Since there are no overdrawn accounts or other negative balance accounts in this example, enter “$0.00.”


42

Column 6: Enter the gross amount actually shown on the sub-control system of record being excluded. In this case enter “$52,000.00” from System 1C. (Exhibit 5, page 47, ITEM 1 ).

Special Note: Credit Line Accounts (loan product type) are included in the amount listed for this Demand Deposit system in Part I on the Demand Deposit Control Summary Bank Totals page. These non-deposit amounts are appropriate for listing in Part II as Other Exclusions to ensure the amounts are not included when the final assessment base is determined (as the balances are already included in the demand deposit control summary totals reported in Part I—master control, embedded sub-control). If the institution has already adjusted (reduced) the system total amount reported in Part I for the amount of non-deposits, there can be no exclusion reported in Part II. The documentation for any item to be listed in Part II - Other Exclusions must include a written explanation within the documentation package that describes the usage of the system for non-deposit purposes and state the basis why the institution believes these amounts should be excluded from the assessment base determination. Below are detailed explanations for completing the information listed for System 1 in Part II of the Deposit Recap as Other Exclusions: Column 1: Leave blank. Column 2: Enter “Other Exclusions.”

Column 3: Enter the number of individual depositor accounts contained in the listed sub-control system of record being excluded. In this case enter “440” from System 1A (Exhibit 3, page 45, ITEM 1 ) Credit Line Accounts Type 83 are included in the Demand Deposit Control Summary Bank Totals and qualify as an "Other Exclusion" from deposits. Column 4: Enter the amount of interest accrued and unpaid contained on the sub-control system of record that contains the amounts being excluded. Since there is no interest accrued and unpaid amount for the Credit Line Accounts system (System 1A), enter “$0.00.” Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in Column 6 associated with the amount being excluded. Since there are no overdrawn accounts or other negative balance accounts in this example, enter “$0.00.” Column 6: Enter the gross amount actually shown on the sub-control system of record being excluded. In this case enter “$15,510,018.89” (Exhibit 3, page 45, ITEM 2 ) “Other Exclusions” can be combined and listed as one amount if an institution has more than one type of “Other Exclusion.”


43

Completing System 1 - Part III of the Deposit Recap (Exhibit 1)

Part III: Total foreign deposits (included in gross system totals and in total Allowable Exclusions) - RC-O Item 3 or DI530: $5,003,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6


# of Deposit



Bal. Total on System None to List for this System

Since System 1 does not include any Foreign Deposits and no foreign deposit amounts were included in Part I or Part II for System 1 no entries are required in Part III under this section for System 1.


44

Exhibit 2 - System 1

Demand Deposit Control Summary Bank Totals PAGE XXX

ABC BANK

PROCESSING DATE 03/31/xxxx

PROCESSING THRU 04/01/xxxx

SYSTEM DATE 03/31/xxxx

CONTROL SUMMARY BANK TOTALS DEMAND DEPOSITS

------------------------------------- ACCOUNT BALANCE INFORMATION -------------------------------- ACTIVITY

BEGINNING BALANCE 8,641 212,644,603..00 CREDITS ENTERED 1,000 2,111,035.00 CREDITS REJECTS 10 9,403.00 + CREDITS POSTED 990 2,101,632.00 2,101,632.00

+ INCREASE ADJUSTMENTS 0.00 0.00

+ OD YEST 1,022,238.00 178 952,375.00 ITEM 1 69,863.00

DEBITS ENTERED 400 810,348.00 DEBITS REJECTS 5 452.00 - DEBITS POSTED 395 809,896.00 809,896.00 - DECREASE ADJUSTMENTS 900.00 900.00 - GEN NSF / OD DEBITS 17 225.00 225.00 - SERVICE CHARGES DEDUCTED 1,446 11,817.00 11,817.00

ACCRUED PAID ON AUTO CLOSED ACCTS 0.00 ACCRUED PAID ON CYCLED ACCTS + TOTAL ACCRUED PAID TODAY 258,330.00

0.00

+/- TRANSFER TO / FROM

NUMBER OF ACCOUNTS 7,001 214,251,590.00

ITEM 2 ITEM 4

----------------------------------------- ACCRUED INTEREST INFORMATION ------------------------------------

BEGINNING BALANCE 273,536.00 + ACCRUED TODAY 12,818.00 - ACCRUED DROPPED TODAY 510.00 + CREDIT ADJUSTMENTS TO ACCRUED 0.00 - DEBIT ADJUSTMENTS TO ACCRUED 0.00 - ACCRUED PAID TODAY 258,330.00 - FED WITHHOLDING TODAY 1,007.00 - STATE TAX WITHHELD TODAY 0.00 - +/- TRANSFER TO / FROM 0.00

ENDING BALANCE 26,507.00 ITEM 3


45

Exhibit 3 - System 1A Credit Line Accounts Type 83 Activity Recap

03/31/xxxx Page 1

ABC BANK

ACTIVITY RECAP TWO CREDIT LINE ACCOUNTS TYPE 83

------------------------------ BALANCE RECAP ------------------------------

ACTIVITY NUMBER AMOUNT PREVIOUS BALANCE 15,698,235.66

- CREDITS POSTED -235,003.00 - CREDITS REJECTS -6,500.00 - INT. PAID CR. ADJ. 0.00 - INS. PAID CR. ADJ. 0.00

- S.C. CR. ADJ. 0.00 - CHANGE OUT 0.00

- CASH ADV. CR. ADJ. 0.00 - LATE FEE CR. ADJ. 0.00

- ANNUAL FEE CR. ADJ 0.00 - CHARGE OFF 0.00

+ CHANGE IN 0.00 + INT. CHARGED 0.00 + INS. CHARGED 0.00

+ SERVICE CHARGES 0.00 + IMMEDIATE TRANS CHG. 0.00

+ INT. PAID DR. ADJ. 0.00 + INS. PAID DR. ADJ. 0.00

+ S.C. DR. ADJ. 0.00 + DEBITS POSTED 53,286.23

+ DEBITS REJECTS 0.00 + TRANSFERS TO DDA 0.00

+ CASH ADVANCE CHARGE 0.00 + LATE FEE CHARGED 0.00

+ CASH ADV. CHG. ADJ. 0.00 + LATE FEE DR. ADJ. 0.00

+ ANNUAL FEE CHARGE 0.00 + ANNUAL FEE DR. ADJ. 0.00

+ REQUEST STMT CHARGE 0.00 + STOP CHARGE 0.00

CURRENT BALANCE 440 ITEM 1 15,510,018.89

ITEM 2


46

Exhibit 4 - System 1B Trust Department Daily Trial Balance

03/31/xxxx ABC Bank

TRUST DEPARTMENT DAILY TRIAL BALANCE

ACCOUNT NAME ACCOUNT NUMBER ACCTS INCOME CASH / INVESTED INC

PRINCIPAL CASH NET CASH

DOE, JOHN 1-235-23 -500,000.00 500,000.00 0.00 SMITH, MARY 1-652-55 -85,000.00 75,000.00 -10,000.00 JONES, TOM 1-456-23 0.00 1,500,000.00 1,500,000.00 BROWN, LARRY 1-989-69 -1,100,000.00 1,000,000.00 -100,000.00 TAYLOR, JANE 1-789-45 0.00 3,600,000.00 3,600,000.00 MURPHY, MIKE 1-545-11 86,000.00 85,500.00 171,500.00 BREWER, TOM 1-858-77 60,000.00 -55,250.00 4,750.00 SMITH, JANE 1-858-69 0.00 2,650,000.00 2,650,000.00 FORD, FRAN 1-888-66 50,000.00 50,000.00 100,000.00 WILLIAMS, JACK 1-256-89 0.00 -25,000.00 -25,000.00

Trust Dep. DDA Account Balance

10 -1,489,000.00 9,380,250.00 7,891,250.00

Note: Deposits are to be reported at gross. In this example the reported totals for trust deposits is $8,026,250.00 Consisting of the NET CASH total of $7,891,250.00 plus the overdraft totals of $135,000.00 (10,000+100,000+25,000).

The total amount of overdrafts would be $135,000.00 ITEM 1

The number of depositor accounts would be 10 ITEM 2


47

Exhibit 5 - System 1C Reciprocal Balance Worksheet

ABC BANK

Bank Account Statement XYZ, NA 1111 Down Street Anywhere, US XXXXX Account Number 5555 Beginning Balance 215,000.00 Deposits and other credits 10,000.00 Checks paid -5,000.00 Other debits 0.00 Ending Balance 220,000.00

XYZ BANK, NA Bank Account Statement

ABC Bank 2222 Up Street Anywhere, US XXXXX Account Number 6666 Beginning Balance 70,000.00 Deposits and other credits 10,000.00 Checks paid -28,000.00 Other debits 0.00 Ending Balance 52,000.00

Due To (XYZ Bank, NA) = $220,000.00 Due From (XYX Bank, NA) = $52,000.00 ITEM 1


48

System 2 – Savings Deposits

Description of System 2 The second example describes a Savings Deposit System which includes accounts with no fixed term and usually a fixed interest rate. Please note that for this example foreign deposits are maintained in System 2A as evidenced by the Savings Deposit System Control Summary, (Exhibit 7 page 53). For illustration purposes, assume that there are 200 customers with foreign deposits in the Savings Deposit System totaling $5,000,000.00 with $3,000.00 in interest accrued and unpaid.

Supporting Documentation: The mock-up supporting documentation for System 2 includes the master control Savings Deposit System Control Summary and the sub-control report evidencing foreign deposits as described above. System 2 – Master Control: “Savings Deposit Control Summary Bank Totals.” This depicts a typical control total summary page that reflects the number of Savings Deposit accounts, the accrued and unpaid interest and total deposit ending balance for the processing date (Exhibit 6 page 52). System 2A – Sub-Control: “Foreign Deposits Type 74 Activity Recap”. This depicts a typical Activity Recap report for product type 74 – Foreign Deposits. The report contains sufficient information to identify the number of foreign deposit accounts, the accrued and unpaid interest and the total Foreign Deposits ending balance for the processing date (Exhibit 7 page 53). Completing System 2 - Part I of the Deposit Recap (Exhibit 1)

The information from the Savings Deposit Control Summary Bank Totals page is transferred to Part I of the Deposit Recap as indicated below. Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: $1,017,576,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #



# of Deposit



Bal. Total on System System 2 Savings Deposits Control Summary Bank Totals 4,015 $263,242.93 $0.00 $292,413,283.00

Below are detailed explanations for completing the information listed for System 2 in Part I of the Deposit Recap.


49

Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case, “System 2” pertains to the second system listed in Part I. Column 2: Enter the actual title that appears on the system of record that contains the amounts being reported. In this case enter “Savings Deposit Control Summary Bank Totals.”

Column 3: Enter the amount of individual depositor accounts contained in the listed system of record. In this case enter “4,015” (Exhibit 6, page 52, ITEM 1 ) Column 4: Enter the amount of interest accrued and unpaid for the system of record that contains the amounts being reported. In this case enter “$263,242.93” (Exhibit 6, page 52, ITEM 2 ). Column 5: Enter the amount of overdrawn balances or other negative balances that reduced the summary balance listed in Column 6. Since there are no overdraft or other negative accounts in this example, enter “0.00.” Column 6: Enter the total deposit amount actually shown on the system of record being reported. In this case enter “$292,413,283.00” (Exhibit 6, page 52, ITEM 3 ) Completing System 2 - Part II of the Deposit Recap (Exhibit 1) Special Note: Documentation must be provided to verify the amount excluded from deposits. The institution needs to verify that the exclusion complies with all regulatory requirements. The information from the Foreign Deposits Type 74 Activity Recap page is transferred to Part II of the Deposit Recap as indicated below. These are foreign deposits included in the amount for Time and Savings Deposits in Part I, and are an allowable exclusion from deposits.


System #


# of Deposit




Below are detailed explanations for completing the information listed for System 2 in Part II of the Deposit Recap under Allowable Exclusions: Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case, “System 2” pertains to the second system listed in Part I.


50

Column 2: Enter the actual title that appears on the master control system of record that contains the amounts being excluded. In this case enter “Savings Deposits Control Summary Bank Totals.” Column 3: Enter the number of individual depositor accounts contained on the sub-control system of record being excluded. In this case enter “200” (Exhibit 7, page 53, ITEM 1 ). Column 4: Enter the amount of interest accrued and unpaid contained on the sub-control system of record being excluded. In this case enter “$3,000.00” (Exhibit 7, page 53, ITEM 2 ). This amount for Foreign Deposits was included in the Savings Deposit Control Summary Bank Totals included in Part I and qualifies as an allowable exclusion.

Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in Column 6 associated with the amounts being excluded. Since there are no overdraft or other negative accounts in this example, enter “$0.00.”

Column 6: Enter the total amount actually shown on the sub-control system of record being excluded. In this case enter “$5,000.000.00” (Exhibit 7, page 53, ITEM 3 ).

Completing System 2 – Part III of the Deposit Recap (Exhibit 1) The information from the Foreign Deposits Type 74 Activity Recap page is transferred to Part III of the Deposit Recap as indicated below. The amount of foreign deposits included in Part I and Part II of the Deposit Recap are also listed here.



# of Deposit




Below are detailed explanations for completing the information listed for System 2 in Part III of the Deposit Recap. Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case enter “System 2” pertains to System 2 listed in Part I and II. Column 2: Enter the actual title that appears on the system of record that contains the amounts being reported. In this case enter “Savings Deposits Control Summary Bank Totals.” Column 3: Enter the number of individual depositor accounts contained on the listed sub-control system of record being reported. In this case enter “200” (Exhibit 7, page 53, ITEM 1 ).


51

Column 4: Enter the amount of interest accrued and unpaid contained on the sub-control system of record being excluded. In this case enter “$3,000.00” (Exhibit 7, page 53, ITEM 2 ). Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in Column 6. Since there are no overdraft or other negative accounts in this example, enter “$0.00.” Column 6: Enter the total deposit amount actually shown on the sub-control system of record being reported. In this case enter “$5,000.000.00” (Exhibit 7, page 53, ITEM 3 ).


52

Exhibit 6 - System 2 Savings Deposit Control Summary Bank Totals

Page xxx ABC BANK

PROCESSING DATE 03/31/xxxx PROCESSING THRU 04/01/xxxx


CONTROL SUMMARY BANK TOTALS SAVINGS DEPOSITS

-------------------------- ACCOUNT BALANCE INFORMATION ----------------------------

BEGINNING BALANCE 292,009,793.00

+ DEPOSITS / AUTO TRANSFERS 327,045.00 + INTEREST PAID 204,863.00 - WITHDRAWALS -351.00 - REDEMPTIONS -52,430.00 - INT CK / ACH WITHDRAWALS -69,267.00 - INTEREST TRANSFERRED -10,352.00 - FEDERAL WITHHOLDING -9.00 - STATE WITHHOLDING 0.00 - PENALTIES TODAY 0.00 - SERVICE CHARGES / FEES 0.00 +/- ADJUSTMENTS 3,991.00 +/- TRANSFERS 0.00

+/- MISC REVERSALS 0.00

ENDING BALANCE 292,413,283.00 ITEM 3

NUMBER OF ACCOUNTS 4,015

ITEM 1

---------------------------------- ACCRUED INTEREST INFORMATION ------------------------------------

BEGINNING BALANCE 335,999.93 + ACCRUED TODAY 111,358.00 - INTEREST PAID TODAY -184,147.00 - MANUAL INTEREST PAYMENTS 0.00 - CLOSING INTEREST PAID 0.00 - ACCRUED DROPPED TODAY .00 + / - ADJUSTMENTS 32.00 + / - TRANSFERS 0.00

+ / - MISC REVERSALS 0.00



53

Exhibit 7 - System 2A Foreign Deposits Type 74 Activity Recap

Page xxx ABC BANK




ACTIVITY RECAP FOREIGN DEPOSITS TYPE 74

-------------------------------- ACCOUNT BALANCE INFORMATION ----------------------------------


+ DEPOSITS / AUTO TRANSFERS 0.00

+ INTEREST PAID 0.00

- WITHDRAWALS 0.00

- REDEMPTIONS 0.00

- INT CK / ACH WITHDRAWALS 0.00

- INTEREST TRANSFERRED 0.00

- FEDERAL WITHHOLDING 0.00

- STATE WITHHOLDING 0.00

- PENALTIES TODAY 0.00

- SERVICE CHARGES / FEES 0.00

+/- ADJUSTMENTS 0.00

+/- TRANSFERS 0.00



NUMBER OF ACCOUNTS 200

ITEM 1

---------------------------------- ACCRUED INTEREST INFORMATION -----------------------------------

BEGINNING BALANCE 3,000.00

+ ACCRUED TODAY 0.00

- ACCRUED DROPPED TODAY 0.00

+ CREDIT ADJUSTMENTS TO ACCRUED 0.00

- DEBIT ADJUSTMENTS TO ACCRUED 0.00

- ACCRUED PAID TODAY 0.00

- FED WITHHOLDING TODAY 0.00

- STATE TAX WITHHELD TODAY 0.00

+ / - TRANSFER TO / FROM



54

System 3 – Time Deposits

Description of System 3 The third example describes a Time Deposit System which includes accounts with a fixed term (often three months, six months, or one to five years), and, usually, a fixed interest rate. Supporting Documentation: The mock-up supporting documentation required to complete all three parts of the Deposit Recap for System 3 is the master control Time Deposit Control Summary Bank Totals. System 3 – Master Control: “Time Deposits Control Summary Bank Totals”. This is a typical control total summary page that reflects the number of Time Deposit accounts, the accrued and unpaid interest and total deposit ending balance for the processing date. (Exhibit 8, page 56) Completing System 3 - Part I of the Deposit Recap (Exhibit 1) The information for the Time Deposit Control Summary Bank Totals page is transferred to Part I of the Deposit Recap as indicated below. Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: $1,017,576,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #



# of Deposit



Bal. Total on System System 3 Time Deposits Control Summary Bank Totals 3,252 $1,984,593.00 $0.00 $490,205,801.75

Below are detailed explanations for completing the information listed for System 3 in Part I of the Deposit Recap. Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case “System 3” as the information pertains to the third system listed in Part I. Column 2: Enter the actual title that appears on the system of record that contains the amounts being reported. In this case enter “Time Deposit Control Summary Bank Totals” (Exhibit 8, page 56). Column 3: Enter the number of individual depositor accounts contained in the listed system of record being reported. In this case enter “3,252” (Exhibit 8, page 56, ITEM 1 ). Column 4: Enter the amount of interest accrued and unpaid for the system of record that contains the amounts being reported. In this case enter “$1,984,593.00” (Exhibit 8, page 56, ITEM 2 ).


55

Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in Column 6. Since there are no overdrawn accounts or other negative accounts for this example, enter “$0.00.”

Column 6: Enter the total deposit amount actually shown on the system of record being reported. In this case enter “$490,205,801.75” (Exhibit 8, page 56, ITEM 3 ) Completing System 3 - Part II of the Deposit Recap (Exhibit 1)


System #


# of Deposit




Since System 3 does not include any Allowable Exclusions, Other Exclusions or Foreign Deposits no entries are required in Part II.




# of Deposit




Since System 3 does not include any Foreign Deposits no entries are required in Part III.


56

Exhibit 8 - System 3 Time Deposit Control Summary Bank Totals

PAGE XXX ABC BANK




CONTROL SUMMARY BANK TOTALS TIME DEPOSITS

-------------------------- ACCOUNT BALANCE INFORMATION ----------------------------


+ DEPOSITS / AUTO TRANSFERS 327,045.00 + INTEREST PAID 204,863.00 - WITHDRAWALS -351.00 - REDEMPTIONS -52,430.00 - INT CK / ACH WITHDRAWALS -69,267.00 - INTEREST TRANSFERRED -10,352.00 - FEDERAL WITHHOLDING -9.00 - STATE WITHHOLDING 0.00 - PENALTIES TODAY 0.00 - SERVICE CHARGES / FEES 0.00 +/- ADJUSTMENTS 3,991.00 +/- TRANSFERS 0.00



NUMBER OF ACCOUNTS 3,252 ITEM 1

------------------------------------ ACCRUED INTEREST INFORMATION --------------------------------

BEGINNING BALANCE 2,059,320.25 + ACCRUED TODAY 109,377.75 - INTEREST PAID TODAY -184,147.00 - MANUAL INTEREST PAYMENTS 0.00 - CLOSING INTEREST PAID 0.00 - ACCRUED DROPPED TODAY .00 + / - ADJUSTMENTS 32.00 + / - TRANSFERS 0.00

+ / - MISC REVERSALS 0.00



57

System 4 – Brokered Certificates of Deposit

Description of System 4 The fourth example describes a Brokered Certificate of Deposit System which includes deposit amounts acquired through a broker or other agent with a fixed term (often three months, six months, or one year), and, usually, a fixed interest rate. Supporting Documentation: The mock-up supporting documentation required to complete all three parts of the Deposit Recap for System 4 is the master control Brokered Certificates of Deposit. System 4 – Master Control: “Brokered Certificate of Deposit.” This depicts a typical worksheet that reflects the number of Brokered Certificates of Deposit accounts, the accrued and unpaid interest and total deposit ending balance for the processing date (Exhibit 9, page 59). Completing System 4 - Part I of the Deposit Recap (Exhibit 1) The information for the Brokered Certificates of Deposit Control Summary Bank Totals page is transferred to Part I of the Deposit Recap as indicated below. Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: $1,017,576,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #



# of Deposit



Bal. Total on System System 4 Brokered Certificates of Deposits 165 $99,615.93 $0.00 $16,000,000.00

Below are detailed explanations for completing the information listed for System 4 in Part I of the Deposit Recap. Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case “System 4” as the information pertains to the fourth system listed in Part I. Column 2: Enter the actual title that appears on the system of record that contains the amounts being reported. In this case enter “Brokered Certificates of Deposit.” Column 3: Enter the number of individual depositor accounts contained in the listed system of record being reported. In this case enter “165” (Exhibit 9, page 59, ITEM 3 ). Column 4: Enter the amount of interest accrued and unpaid for the system of record that contains the amounts being reported. In this case enter “$99,615.93” (Exhibit 9, page 59. ITEM 2 ).


58

Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in Column 6. Since there are no overdrawn accounts or other negative accounts for this example, enter “$0.00.”

Column 6: Enter the gross deposit amount actually shown on the system of record being reported. In this case enter “$16,000,000.00” (Exhibit 9, page 59, ITEM 1 ). Completing System 4 - Part II of the Deposit Recap (Exhibit 1)


System #


# of Deposit








# of Deposit






59

Exhibit 9 - System 4 Brokered Certificates of Deposit

Institution Name: ABC Bank Certificate Number: 11111 As of Date: 3/31/xxxx 204900 - Brokered CD's

Date Description Amount Valuation Allowance Balance Interest

Accrual # of DepositorAccounts

2/15 Deposits purchased from XXX 10,000,000.00 -100,000.00 9,900,000.00 45,512.30 90 3/1 Deposits purchased from XXX 4,000,000.00 -40,000.00 3,960,000.00 36,111.20 45

3/22 Deposits purchased from XXX 2,000,000.00 -20,000.00 1,980,000.00 17,992.43 30

3/31 Totals 16,000,000.00 ITEM 1 -160,000.00 15,840,000.00 99,615.93 ITEM 2 165 ITEM 3


60

System 5 – Mortgage Escrows

Description of System 5 The fifth example involves Mortgage Escrows (System 5) which are commonly found in the mortgage loan system. Mortgage loan systems typically maintain escrow accounts for the purpose of holding funds received from borrowers and held for the payment of real estate taxes and property insurance. In general, Section 3(l) of the FDI Act states that the term “deposit” means the unpaid balance of money or its equivalent received or held by a depository institution or savings association in the usual course of business and for which it has given or is obligated to give credit for a special or specific purpose. Mortgage escrows meet this definition of deposits. This example illustrates a type of deposit that is found in an automated non-deposit system. Additional examples of types of deposits that might be found in automated non-deposit systems are credit balances on credit cards and undisbursed loan proceeds. The activity of Mortgage Escrows is supported by the control total summary page of the mortgage loan trial balance (Master Control) used to track the total escrow balance and total number of escrow accounts outstanding for each business day; and provide the source and detail for balancing (refer to Exhibit 10 page 63). Special Note: Financial institutions routinely make payments (advances) for insurance, taxes, etc., whether or not they have actually received the escrow payments from their customers. This may result in overdrawn amounts in some of the escrow accounts. Those overdrafts should not reduce the escrow deposits reported. Some financial institutions have traditionally reported the amount of escrows net of overdrafts which is incorrect. Mortgage escrows are to be reported at gross. Section 7(a) (4) of the FDI Act provides that each insured institution shall report the total amount of the liability of the institution, without any deduction for indebtedness of depositors or creditors.

For illustration purposes, assume that there are 388 mortgage escrow accounts that represent net escrows in the amount of $917,667.00 with negative escrow balances of $269,177.00 and accrued interest of $16,969.00.

Supporting Documentation: The mock-up supporting documentation required to complete System 5 is the master control summary page from the Mortgage Loan Trial Balance providing the escrow amounts. System 5 – Master Control: “Mortgage Loan Trial Balance”. This depicts a typical control total summary page that reports the escrow balance, escrow advances, escrow accrued interest and the number of escrow accounts for the processing date (Exhibit 10 page 63).


61

Completing System 5 - Part I of the Recap (Exhibit 1) The information for Mortgage Escrow is transferred to Part I of the Deposit Recap as indicated below. Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: $1,017,576,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #



# of Deposit



Bal. Total on System System 5 Mortgage Loan Trial Balance 388 $16,969.00 $269,177.00 $917,667.00

Below are detailed explanations for completing the information listed for System 5 in Part I of the Deposit Recap. Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case “System 5” as the information pertains to the fifth system listed in Part I. Column 2: Enter the actual title that appears on the system of record that contains the amounts being reported. In this case enter “Mortgage Loan Trial Balance.” Column 3: Enter the number of escrow accounts contained in the listed system of record being reported. In this case enter “388” (Exhibit 10, page 63, ITEM 4 ). Column 4: Enter the amount of interest accrued and unpaid for the system of record that contains the amounts being reported. In this case enter “$16,969.00” (Exhibit 10, page 63, ITEM 3 ). Column 5: Enter the amount of negative escrow accounts that reduced the summary balance listed in Column 6. In this case enter “$269,177.00” (Exhibit 10, page 63, ITEM 2 ). Column 6: Enter the escrow deposit amount actually shown on the system of record being reported. In this case enter “$917,667.00” (Exhibit 10, page 63, ITEM 1 ).

Completing System 5 - Part II of the Deposit Recap (Exhibit 1)


System #


# of Deposit





62

Since System 5 does not include any Foreign Deposits or Other Exclusions no entries are required in Part II.




# of Deposit




Since System 5 does not include any Foreign Deposits in Part I or Part II for System 5 no entries are required in Part III.


63

Exhibit 10 - System 5 Mortgage Loan Trial Balance

03/31/xxxx ABC BANK

MORTGAGE LOAN TRIAL BALANCE

Loan Type Current Principal Balance

Loan Interest Accrual

Escrow Balance

Escrow Advance

Escrow InterestAccrual

Escrow Loan Count

11 9,644,416.00 24,068.00 517,340.00 -117,045.00 10,967.00 152 21 4,425,523.00 4,581.00 201,781.00 -15,867.00 2,679.00 87 31 1,051,586.00 7,325.00 87,276.00 -39,134.00 1,001.00 19 41 381,027.00 2,029.00 39,035.00 -1,010.00 487.00 2 51 1,441,074.00 18,372.00 43,264.00 -86,563.00 1,272.00 123 61 300,303.00 1,196.00 28,971.00 -9,558.00 563.00 5

17,243,929.00 57,571.00 917,667.00 -269,177.00 16,969.00 388

ITEM 1 ITEM 2 ITEM 3 ITEM 4


64

System 6 – Security Deposits

Description of System 6

The sixth example involves Security Deposits (System 6) which are commonly found in a worksheet, ledger card, or other non-deposit system. A security deposit is money held by an insured institution on behalf of a customer as protection against property damages or loss (such as an institution renting office space in its building to another business). The deposit is usually refundable upon request or at the end of a designated time period if certain terms and conditions are met. In general, Section 3(l) of the FDI Act states that the term “deposit” means the unpaid balance of money or its equivalent received or held by a depository institution or savings association in the usual course of business and for which it has given or is obligated to give credit for a special or specific purpose. Security Deposits meet the definition of deposits. The activity of Security Deposits is supported by the control total summary page of a non deposit system of record, worksheet or ledger card (Master Control) used to support and balance the deposit amounts. The source of activity should provide sufficient detail to identify individual deposit customers, security amounts, and a total security account balance for each business day. For illustration purposes, assume there are a list of ten security deposits whose aggregate sum represent total security deposits of $40,000. Supporting Documentation: The mock-up supporting documentation required to complete System 6 is the master control summary page from the Security Deposit worksheet or ledger card providing the security deposit balance. System 6 – Master Control: “Security Deposit Account Balance” This depicts a typical control total summary page that reflects the number of security deposits and the total balance for the processing date (Exhibit 11 page 67). Completing System 6 - Part I of the Deposit Recap (Exhibit 1)

The information for Security Deposits is transferred to Part I of the Deposit Recap as indicated below. Part I: Deposit system totals before exclusions - RC-O Item 1 or DI510: $1,017,576,000.00 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6

System #



# of Deposit



Bal. Total on System System 6 Security Deposits Account Balance 10 $0.00 $0.00 $40,000.00


65

Below are detailed explanations for completing the information listed for System 6 in Part I of the Deposit Recap. Column 1: Enter the system number that includes the amount to be listed on the Deposit Recap. In this case “System 6” as the information pertains to the sixth system listed in Part I. Column 2: Enter the actual title that appears on the system of record that contains the amounts being reported. In this case enter “Security Deposits Account Balance.” Column 3: Enter the number of security deposit accounts contained in the listed system of record being reported. In this case enter “10” (Exhibit 11, page 67, ITEM 2 ). Column 4: Enter the amount of interest accrued and unpaid for the system of record that contains the amounts being reported. Since, there is no interest accrued and unpaid for this example, enter “$0.00.” Column 5: Enter the amount of overdrawn accounts or other negative balance accounts that reduced the summary balance listed in Column 6. Since there are no overdrawn accounts or other negative accounts for this example, enter “$0.00.” Column 6: Enter the gross security deposit amount actually shown on the system of record being reported. In this case enter “$40,000.00” (Exhibit 11, page 67, ITEM 1 ). Completing System 6 - Part II of the Deposit Recap (Exhibit 1)


System #


# of Deposit






66




# of Deposit






67

Exhibit 11 - System 6

Security Deposits Account Balance 03/31/xxxx

ABC BANK SECURITY DEPOSITS

ACCOUNT BALANCE Account # 2XXXX

Date Description Deposit Amount

Security Balance

# of Security Accounts

1-Jan B & B Maid Brigade Bldg II, Unit 7 4,500.00 4,500.00 1

2-Jan DLR Investment Agency Bldg IV, Unit 1 3,000.00 7,500.00 1

3-Jan JV Title Company Bldg II, Unit 5-6 5,500.00 13,000.00 1

4-Jan A - 1 Water Consultants Bldg I, Unit 8-9 3,700.00 16,700.00 1

7-Jan Young's Employment Solutions Bldg V, Unit 5 2,500.00 19,200.00 1

8-Jan C&S Surf Shop Bldg IV Unit 2 3,400.00 22,600.00 1

9-Jan JN Consulting Firm Bldg II Unit 1-3 7,000.00 29,600.00 1

10-Jan ThinkPad INC, Bldg III, Unit 10 3,000.00 32,600.00 1

11-Jan First Home Buyers Inc Bldg I, Unit 1 4,400.00 37,000.00 1

14-Jan Loretta's Dance Studio Bldg 3,000.00 40,000.00 10

ITEM 1 ITEM 2


68

GROSS TOTAL AVERAGE DEPOSIT REPORTING SUMMARY

(“Average Summary”)

FDIC staff is available to provide advice and assistance in integrating daily average deposit reporting into an institution’s internal control procedures. For this sample, the hypothetical institution reports daily average deposits and exclusions. The Average Summary summarizes the information provided on the Deposit Recap for each reporting day of the quarter and is used to validate the calculation of the gross total daily average deposits and exclusions. This example illustrates how an institution could complete the Average Summary listing by using the Deposit Recap. In this example, the information from the March 31 Deposit Recap is used to fill out the March 31 line on the Average Summary listing. The reporting used in the March 31 example could be applied to the other dates on the Average Summary listing. Below are the detailed explanations for completing the March 31 line on the Average

Summary: Gross Total Average Deposit Reporting Summary Institution: 11111 - ABC Bank Quarter Begin: 1/1/2008 Call Rpt/Quarter End: 3/31/2008 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6 Col 7 Col 8

Day Date

# of Deposit

Accounts - Part I

Total Deposit Liabilities Before

Exclusions (Gross) - Part I

# of Deposit

Accounts - Part II


Foreign Deposits) - Part

II

# of Deposit

Accounts - Part III




91 Monday, March 31, 2008 14,840 $1,017,575,821.61 640 $20,565,018.89 200 $5,003,000.00

Column 1: It could be helpful to list the sequential day of the quarter (in this illustration the 91st day of the quarter). Column 2: Enter the date of the applicable daily Deposit Recap. Since the rows for non-business days (Saturdays, Sundays, holidays, etc.) are populated with the previous day’s deposit amounts, it could be helpful to include the day of the week (as illustrated above) or note holidays. Column 3: Enter the total in Part I, Column 3 (# of Accounts) of the March 31 Deposit Recap. In this case enter “14,840” (Exhibit 1, page 37). Column 4: List the sum of the total lines for Part I, Columns 4, 5 and 6 of the March 31 Deposit Recap. In this case enter “$1,017,575,821.61” (Exhibit 1 page 37). Column 5: List the total in Part II, Column 3 (# of Accounts) of the March 31 Deposit Recap. In this case enter “640” (Exhibit 1 page 37).


69

Column 6: List the sum of the total lines for Part II, Columns 4, 5 and 6 of the March 31 Deposit Recap. In this case enter “$20,565,018.89” (Exhibit 1 page 37) Column 7: List the total in Part III, Column 3 (# of Accounts) of the March 31 Deposit Recap. In this case enter “200” (Exhibit 1 page 37) Column 8: List the sum of the total lines for Part III, Columns 4, 5 and 6 of the March 31 Deposit Recap. In this case enter “$5,003,000.00” (Exhibit 1 page 37) For days the institution is closed for business (e.g., Saturdays, Sundays, holidays or any day where no transactions are posted to the general ledger) the amounts outstanding from the previous business day would be used. An example of this is shown for the dates of January 18 through January 21 on the Average Summary. After all days of the quarter are recorded on the spreadsheet, total Columns 3, 5, and 7 and divide by the number of days in the quarter and round to thousands. For this example, the average for Column 3 is “1,016,186” which will confirm the amount reported on Schedule RC-O, Line 4 or Schedule DI, Line DI540. The average for Column 7 is “20,116” which will confirm the amount reported on Schedule RC-O, Line 5 or Schedule DI, Line DI550. The average for Column 7 is “4,913” which will confirm the amount reported on Schedule RC-O, Line 6 or Schedule DI, Line DI560. During a Deposit Review institutions will be asked to send the Average Summary or similar spreadsheet to the FDIC (through EFE) for use as a basis for validating the institution’s quarterly daily average reporting. In addition, subsequent to the original request for a Deposit Review, additional days might be selected to verify the amounts recorded in the Average/Daily Summary for those days selected.


70

Exhibit 11 – Gross Total Average Deposit Reporting Summary (“Average Summary”)

Gross Total Average Deposit Reporting Summary Institution: 11111 - ABC Bank Quarter Begin: 1/1/2008 Call Rpt/Quarter End: 3/31/2008 Col 1 Col 2 Col 3 Col 4 Col 5 Col 6 Col 7 Col 8

Day Date

# of Deposit

Accounts - Part I

Total Deposit Liabilities Before

Exclusions (Gross) - Part I

# of Deposit

Accounts - Part II


Foreign Deposits) - Part

II

# of Deposit

Accounts - Part III




1 Tuesday, January 01, 2008 12,563 $1,013,750,000.52 639 $20,500,000.25 199 $5,010,000.10

2 Wednesday, January 02, 2008 12,666 $1,013,500,000.25 633 $20,411,000.36 199 $4,901,000.23

3 Thursday, January 03, 2008 12,725 $1,013,810,001.23 638 $20,402,050.32 198 $4,922,325.36

4 Friday, January 04, 2008 12,888 $1,013,700,502.23 634 $20,303,000.89 198 $4,925,250.26

5 Saturday, January 05, 2008 12,888 $1,013,700,502.23 634 $20,303,000.89 198 $4,925,250.26

6 Sunday, January 06, 2008 12,888 $1,013,700,502.23 634 $20,303,000.89 198 $4,925,250.26

7 Monday, January 07, 2008 12,963 $1,013,700,046.90 637 $20,509,000.52 200 $5,018,585.56

8 Tuesday, January 08, 2008 12,989 $1,013,300,000.56 637 $20,412,150.98 200 $4,996,310.78



11 Friday, January 11, 2008 13,066 $1,013,750,006.30 637 $20,311,175.74 199 $4,961,115.88


13 Sunday, January 13, 2008 13,066 $1,013,750,006.30 637 $20,311,175.74 199 $4,961,115.88

14 Monday, January 14, 2008 13,232 $1,014,390,001.23 636 $20,020,125.23 198 $4,991,110.44

15 Tuesday, January 15, 2008 13,332 $1,014,555,000.23 635 $20,100,000.25 201 $4,980,363.65



18 Friday, January 18, 2008 13,560 $1,014,800,056.99 635 $20,090,500.87 200 $4,915,252.33


20 Sunday, January 20, 2008 13,560 $1,014,800,056.99 635 $20,090,500.87 200 $4,915,252.33

21 Monday, January 21, 2008 13,560 $1,014,800,056.99 635 $20,090,500.87 200 $4,915,252.33

22 Tuesday, January 22, 2008 13,622 $1,014,890,090.26 635 $19,900,275.22 200 $4,891,000.10



25 Friday, January 25, 2008 13,654 $1,015,620,595.00 635 $19,602,000.78 200 $4,925,250.26


27 Sunday, January 27, 2008 13,654 $1,015,620,595.00 635 $19,602,000.78 200 $4,925,250.26

28 Monday, January 28, 2008 13,724 $1,015,921,113.22 636 $20,009,000.11 199 $4,855,585.56

29 Tuesday, January 29, 2008 13,726 $1,015,912,392.30 636 $19,901,000.12 199 $4,966,310.78



32 Friday, February 01, 2008 13,766 $1,015,911,100.23 636 $19,702,050.28 200 $4,961,115.88

33 Saturday, February 02, 2008 13,766 $1,015,911,100.23 636 $19,702,050.28 200 $4,961,115.88

34 Sunday, February 03, 2008 13,766 $1,015,911,100.23 636 $19,702,050.28 200 $4,961,115.88

35 Monday, February 04, 2008 13,799 $1,016,319,200.96 638 $20,700,050.15 200 $4,991,110.44

36 Tuesday, February 05, 2008 13,802 $1,016,365,500.85 638 $20,500,300.33 200 $4,980,363.65


71

37 Wednesday, February 06, 2008 13,866 $1,016,211,100.00 638 $20,400,000.58 200 $4,955,252.44

38 Thursday, February 07, 2008 13,867 $1,016,500,000.85 638 $20,405,050.11 200 $4,925,363.22

39 Friday, February 08, 2008 13,877 $1,016,221,100.44 638 $20,307,000.22 200 $4,915,252.33


41 Sunday, February 10, 2008 13,877 $1,016,221,100.44 638 $20,307,000.22 200 $4,915,252.33

42 Monday, February 11, 2008 13,912 $1,016,202,521.25 638 $20,107,000.46 199 $4,915,115.99




46 Friday, February 15, 2008 13,977 $1,016,523,550.98 639 $20,276,075.58 200 $4,925,250.26


48 Sunday, February 17, 2008 13,977 $1,016,523,550.98 639 $20,276,075.58 200 $4,925,250.26

49 Monday, February 18, 2008 13,977 $1,016,523,550.98 639 $20,276,075.58 200 $4,925,250.26




53 Friday, February 22, 2008 14,072 $1,016,154,215.00 638 $19,997,850.25 199 $4,951,115.88


55 Sunday, February 24, 2008 14,072 $1,016,154,215.00 638 $19,997,850.25 199 $4,951,115.88

56 Monday, February 25, 2008 14,088 $1,016,599,200.99 638 $19,977,700.99 199 $4,961,110.44




60 Friday, February 29, 2008 14,115 $1,016,622,280.23 638 $19,935,030.00 200 $4,915,252.33

61 Saturday, March 01, 2008 14,115 $1,016,622,280.23 638 $19,935,030.00 200 $4,915,252.33

62 Sunday, March 02, 2008 14,115 $1,016,622,280.23 638 $19,935,030.00 200 $4,915,252.33

63 Monday, March 03, 2008 14,233 $1,017,628,880.89 639 $20,555,990.42 200 $4,915,115.99

64 Tuesday, March 04, 2008 14,256 $1,017,630,540.10 639 $20,990,100.11 200 $4,900,000.10

65 Wednesday, March 05, 2008 14,325 $1,017,654,600.23 639 $20,128,885.49 200 $4,901,000.23

66 Thursday, March 06, 2008 14,366 $1,017,655,800.55 639 $20,166,675.33 199 $4,822,325.36

67 Friday, March 07, 2008 14,370 $1,017,664,650.32 639 $20,207,870.52 199 $4,725,250.26

68 Saturday, March 08, 2008 14,370 $1,017,664,650.32 639 $20,207,870.52 199 $4,725,250.26

69 Sunday, March 09, 2008 14,370 $1,017,664,650.32 639 $20,207,870.52 199 $4,725,250.26

70 Monday, March 10, 2008 14,446 $1,017,665,200.00 639 $20,525,800.25 200 $4,388,585.56

71 Tuesday, March 11, 2008 14,449 $1,017,660,050.00 639 $19,000,975.24 200 $4,532,310.78

72 Wednesday, March 12, 2008 14,510 $1,017,771,125.00 638 $19,852,630.26 200 $4,966,980.00

73 Thursday, March 13, 2008 14,512 $1,017,690,025.23 638 $19,999,900.85 200 $4,962,655.77

74 Friday, March 14, 2008 14,523 $1,017,723,000.09 638 $19,908,880.74 200 $4,961,115.88

75 Saturday, March 15, 2008 14,523 $1,017,723,000.09 638 $19,908,880.74 200 $4,961,115.88

76 Sunday, March 16, 2008 14,523 $1,017,723,000.09 638 $19,908,880.74 200 $4,961,115.88

77 Monday, March 17, 2008 14,589 $1,017,798,150.00 638 $20,155,000.52 200 $4,960,110.44

78 Tuesday, March 18, 2008 14,588 $1,017,840,300.23 638 $20,266,025.36 200 $4,956,363.65

79 Wednesday, March 19, 2008 14,641 $1,017,781,200.38 638 $20,122,200.66 200 $4,955,252.44

80 Thursday, March 20, 2008 14,655 $1,017,885,000.39 638 $20,000,150.65 200 $4,925,363.22

81 Friday, March 21, 2008 14,689 $1,017,846,500.06 639 $20,122,275.55 200 $4,915,252.33

82 Saturday, March 22, 2008 14,689 $1,017,846,500.06 639 $20,122,275.55 200 $4,915,252.33

83 Sunday, March 23, 2008 14,689 $1,017,846,500.06 639 $20,122,275.55 200 $4,915,252.33

84 Monday, March 24, 2008 14,733 $1,017,824,205.90 639 $20,158,558.39 200 $4,912,115.99


72

85 Tuesday, March 25, 2008 14,788 $1,017,857,430.40 640 $20,299,233.40 200 $4,900,001.65

86 Wednesday, March 26, 2008 14,796 $1,017,999,600.00 640 $20,223,215.88 200 $4,831,412.24

87 Thursday, March 27, 2008 14,793 $1,017,960,700.00 640 $20,100,050.45 200 $4,805,150.00

88 Friday, March 28, 2008 14,802 $1,017,957,400.00 640 $20,099,400.00 200 $4,800,075.12

89 Saturday, March 29, 2008 14,802 $1,017,957,400.00 640 $20,099,400.00 200 $4,800,075.12

90 Sunday, March 30, 2008 14,802 $1,017,957,400.00 640 $20,099,400.00 200 $4,800,075.12

91 Monday, March 31, 2008 14,840 $1,017,575,821.61 640 $20,565,018.89 200 $5,003,000.00

Daily Average $1,016,185,863.78 $20,116,152.33 $4,913,498.65