The rule is about resolvability
Part 370 applies to insured depository institutions with at least two million deposit accounts. It requires recordkeeping and information technology capabilities sufficient for the FDIC to determine deposit-insurance coverage promptly if a bank fails. It does not change the statutory insurance limit; it makes account, ownership and beneficial-interest records usable at scale. [1][2]
Insurance is determined by depositor and ownership category, not simply by account count or brand. A bank must be able to aggregate accounts correctly, identify beneficiaries and preserve ownership information. For fintech programs, the insured bank remains responsible for its records even when a platform collects onboarding data or displays balances. Pass-through coverage depends on records and actual agency relationships, not a marketing claim. [1][3]
Data lineage and an illustrative failure
Consider a customer with $150,000 in an individual account and $150,000 in a qualifying joint account. The categories can receive separate coverage if ownership requirements are met and records support the classification. If a program bank stores the customer name in one system, beneficiary status in another and ledger balances in a partner file, stale identifiers or duplicate records can prevent timely aggregation. This example omits other accounts and exceptions. [1][3]
Institutions need a golden-source mapping among deposit core, subledger, partner program, ownership codes, transaction history and legal documentation. Tests should include missing tax IDs, duplicate people, omnibus accounts, closed accounts, accrued interest and data received from third parties. Reconciliation must prove both completeness and the ability to produce an accurate depositor-level view. [1]
Costs, trade-offs and evidence
The rule can require substantial systems work, data governance and recurring testing, especially for banks with many program managers or nontraditional ownership structures. More detail improves resolution but raises privacy, vendor-management and operational complexity. Useful tests measure retrieval time and exception rates, then reconcile sampled calculations to legal categories rather than merely confirming that a file exported. [1][2]
Part 370 compliance does not guarantee that every depositor is insured, nor does it guarantee a particular failure-resolution outcome. New FDIC rules or amendments can change thresholds and requirements. A bank should distinguish its own compliance status from a program partner’s assertions, and consumers should use the FDIC’s official calculator and coverage guidance.
Sources
- 12 C.F.R. Part 370 — Recordkeeping for Timely Deposit Insurance DeterminationOfficial textBack to text: ↑1↑2↑3↑4↑5↑6
- FDIC — Part 370 recordkeeping resourceOfficial sourceBack to text: ↑1↑2↑3
- FDIC — Deposit Insurance FAQsOfficial sourceBack to text: ↑1↑2