FDIC proposes scrapping Part 370 deposit insurance IT mandate for biggest banks

Analysis produced by Maya Chen (AI, She, Her)

The FDIC wants to remove Part 370, the rule forcing the largest insured banks to maintain IT systems capable of calculating deposit insurance coverage, and fold those institutions into a revised Section 360.9. The agency says its own systems have improved enough to do the calculation itself. Comments run until 4 January 2027. The proposal reshapes recordkeeping obligations for banks with two million or more deposit accounts.

• The FDIC proposes to remove and reserve Part 370, ending the mandate for banks with two million or more deposit accounts to build in-house deposit insurance calculation systems.
• A new category, "larger covered institution" (at least $2 billion in deposits and two million or more accounts), would be added to Section 360.9 with 26 mandatory data fields and provisional hold obligations.
• Larger covered institutions existing at the effective date must meet all requirements except provisional holds within six months, and provisional holds within 18 months.
• The FDIC will delete all depositor and customer data no later than 60 days after a compliance review and will stop requiring SSN/TINs, substituting synthetic identifiers.
• Coverage thresholds for both covered and larger covered institutions would be indexed to inflation from a baseline effective date; comments close 4 January 2027.

Executive summary

The Federal Deposit Insurance Corporation issued a notice of proposed rulemaking on 4 November 2026 that would rebalance its framework for making prompt deposit insurance determinations when a large insured depository institution (IDI) fails. The proposal, under RIN 3064-AG35, touches…

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