360 likes | 677 Views
D1 Total Time Deposits F1 Large Time Deposits BB1 Non-Personal Savings & Time. Table of Contents. D1 – Total Time Deposits F1 – Large Time Deposits BB1 -Non-Personal Time & Savings Deposits Common Reporting Errors Legitimate Differences vs. Call Reporting. D1 Total Time Deposits.
E N D
D1 Total Time DepositsF1 Large Time DepositsBB1 Non-Personal Savings & Time
Table of Contents • D1 – Total Time Deposits • F1 – Large Time Deposits • BB1 -Non-Personal Time & Savings Deposits • Common Reporting Errors • Legitimate Differences vs. Call Reporting
D1 Total Time Deposits • Description • Common types • Reporting • Exclusions
Description • Time Deposit Musts • At least a 7 day Maturity and • Mandatory penalty for withdrawals occurring within 6 days of deposit (at least a 7 day simple interest penalty is applied to the withdrawn funds)
Common Types • Deposits • At least a 7-day maturity • 7-day simple interest penalty on withdrawals within first 6 days of deposit • Types • Certificates of Deposit (CD) including Roll-Over Certificates • IRAs & Keogh Plans • Escrow Accounts • Passbook Accounts • Compensating balances/Collateral • Club Accounts
Common Types • Primary Obligations • Borrowing from non-exempt entity • Issued in at least 7 day maturities • Types • Repurchase Agreements collateralized with non- U.S. government or agency securities • Promissory notes • Commercial Paper
Personal Entire beneficial interest held by natural person and Statement that it is not transferable Non-Personal Any beneficial interest held by non-natural person or Transferable or Lack of not transferable statement Common Types
Transferable Ownership may be transferred or Time deposit which does not state on its face that ownership is non-transferable Non-Transferable Time deposit which states on its face that ownership is non-transferable Exceptions Collateral for defaulted loan Legal circumstances Common Types
Interest Bearing Report time deposits that are interest bearing and Report all interest that has been credited to the customer’s account Non-Interest Bearing Report time deposits that are non-interest bearing Common Types
Reporting • Issued on discount basis • Bank receives $96k in exchange for CD issued with a $100k face value • Only initially report the $96k received at issuance • Report interest earned as it is credited
Reporting • Pre-paid interest • Credit Union receives $10k in exchange for CD with face value of $10k and prepaid $500 interest • Report the $10k face value
Matured time deposits Accrued interest not credited U.S. government or agency guaranteed Repurchase agreements Federal Reserve Bank borrowings FHLB borrowings Primary obligations with exempt entities Common Items to Exclude
F1 Large Time Deposits • 1) Description • 2) Brokered Deposits • 3) Exercise • 4) Exclusions
Included in D1 Greater than or equal to $100k Report entire amount of the large time deposit Include interest credited or paid Description
Brokered Deposits • Report in F1 only the portion of the deposit in amounts of $100k or more that is credited to a single depositor • Broker records made available
Exercise • Example • FR2900 Seminar Bank sells $150k brokered CD to Broker Ron. Broker Ron then sells shares of this CD to the following customers: • Customer Mike $125k • Customer Lisa $15k • Customer Fonda $5k • Customers Mandy and Gina $2.5k each • What is reported in line item D1? • What is reported in line item F1? $150k $125k
Exercise • The $150k Brokered CD sold the following way: • Customer Mike purchased his from Broker Ron: • 12 cd’s @ $10k each • 1 cd @ $5k • Customer Lisa’s $15k • Customer Fonda $5k • Customers Mandy and Gina $2.5k each • What is reported in line item D1? • What is reported in line item F1? $150k $0
Exclusions • All items that do not meet the definition of a time deposit • Time deposits less than $100k • Combined customer deposits totaling $100k or more
BB1 Total Non-Personal Savings & Time Deposits • When to Report • Description • Exclusion
When to Report • Annual item • FR2900 weekly report • Close of business June 30th of each year • FR2900 quarterly report • Close of business on the Monday of the June report week
Description • Savings (C1) and Time Deposits (D1) • Funds in which any beneficial interest is held by a depositor that is not a natural person or • Funds are transferable • Brokered deposits if broker has not supplied individual deposit information
Exclusions • IRAs, Keogh Plan, and similar accounts held by an employer, but the beneficial interest is for a natural person • Escrow accounts if depositor is natural person • Trust funds reported if entire beneficial interest held by natural person • Club accounts held by natural persons
D1 & F1 Common Reporting Errors • All Brokered CDs listed in line item F1 • Allow withdrawals within first 7 days • Line item F1 < $100k • Subtracting out first $100k from F1 • Reporting as time deposit based on title of account
FR2900 (D1/F1) Includes primary obligations with original maturities of 7 days or more as deposits FR2900 (F1) Includes brokered deposit participated out in amounts of $100k FFIEC 031/041 Primary obligations are considered borrowings and are not reported as deposits FFIEC 031/041 Does not include these in the corresponding line item FR2900 vs. FFIEC 031/041
FR2900 (D1) Include primary obligation with original maturity of 7 days or more as deposit IRA and Keogh plans in form of time deposit Includes non-member deposits NCUA 5300 Does not include primary obligation as deposit All IRA and Keogh plans Does not include non-member deposit in corresponding line item FR2900 vs. NCUA 5300
FR2900 Includes primary obligations with original maturities of 7 days or more OTS 1313 Does not include primary obligations as deposits FR2900 vs. OTS 1313