The FDIC has recently extended the comment period for proposed recordkeeping requirements for FDIC-insured institutions with at least 2 million deposit accounts. The FDIC’s notice of proposed rulemaking from February 26, 2016 solicited comments from the general public and the industry regarding this proposal. After the 30-day extension, the comment period now will close on June 25, 2016.

In our March 2016 article, we discussed this proposal, which is intended to facilitate quick payment of insured deposits if large insured banks fail: http://www.mofo.com/~/media/Files/Newsletter/2016/03/160331StructuredThoughts.pdf. In addition, the FDIC has made its report on the estimated cost of compliance available, which is intended to aid commenters. The report may be found here