We do not believe that banks may reduce uninsured deposits to reflect collateralization of deposits by pledged assets when reporting estimated uninsured deposits on their Call Reports. If you have subtracted collateralized amounts from uninsured deposits on Call Reports in the past, we believe you must amend these Call Reports as advised in the FDIC’s FIL.

The FDIC’s FIL states that it is incorrect for a bank to reduce “the amount of reported uninsured deposits . . . to reflect collateralization of deposits by pledged assets.” The FIL also restates the FFIEC’s Call Report instructions, which direct banks to make a reasonable estimate of their uninsured deposits for deposit accounts with collateralized deposits. The FIL instructs institutions that have incorrectly reported uninsured deposits to “amend their Call Reports by making the appropriate changes to the data, and submitting the revised data file to the Central Data Repository (CDR) using the same processes as the original filing.”

For resources related to our guidance, please see:

• FDIC FIL-37-2023, Estimated Uninsured Deposits Reporting Expectations (July 24, 2023) (“In reporting uninsured deposits, if an IDI has deposit accounts with balances in excess of the federal deposit insurance limit that it has collateralized by pledging assets, such as deposits of the U.S. Government and of states and political subdivisions in the U.S., the IDI should make a reasonable estimate of the portion of these deposits that is uninsured using the data available from its information systems.”)

• FFIEC Call Report Instructions (FFIEC 031 and 041), Schedule RC-0, item 2(5), page 400 (March 2023) (“The bank’s estimate of its uninsured deposits should be reported in accordance with the following criteria. . . . (5) If the bank has deposit accounts with balances in excess of the federal deposit insurance limit that it has collateralized by pledging assets, such as deposits of the U.S. Government and of states and political subdivisions in the U.S. (which must be reported in Schedule RC-E, items 2 and 3, and, on the FFIEC 031 report form, in Schedule RC-E, part II, item 5, if applicable), the bank should make a reasonable estimate of the portion of these deposits that is uninsured using the data available from its information systems.”)

• FDIC FIL-37-2023, Estimated Uninsured Deposits Reporting Expectation (July 24, 2023) (“If your institution incorrectly reduced the amount of reported uninsured deposits, for example, to reflect collateralization of deposits by pledged assets or by excluding intercompany deposit balances of subsidiaries, those reports are inaccurate. Consistent with the requirement to file accurate Call Reports, IDIs that have incorrectly reported uninsured deposits should amend their Call Reports by making the appropriate changes to the data, and submitting the revised data file to the Central Data Repository (CDR) using the same processes as the original filing. Institutions can submit up to three years of revisions, or more, if appropriate.”)