Last Thursday, the FDIC issued a draft handbook for organizers of de novo insured depository institutions. The handbook provides an explanation of the process for submitting an application to the FDIC in order to offer FDIC-insured deposit products. The handbook is relevant for any person or company that is interested in a bank charter and proposing to accept insured deposits as a source of funding.
The FDIC is requesting comment on the handbook, including in response to the following questions:
- Does the handbook provide an organizer with sufficient clarity, transparency, and understanding with respect to the requirements, procedures, and processes for establishing an insured depository institution?
- Does the handbook adequately address the requirements, procedures, and processes for establishing an insured depository institution during the primary phases: pre-filing activities, the application process, and pre-opening activities?
- Does the handbook appropriately address the information needs of organizers who are experienced bankers, as well as the information needs of other organizers, such as certain proposed investors or directors, who may not have experience in banking?
- Is the inclusion of comments from successful bank Chief Executive Officers regarding de novo formation helpful and, if so, should the discussion be expanded?
Comments are due by February 20, 2017.