The Board is considering a proposal for FDIC staff to brief the Board on any deposit insurance or merger application filed with the FDIC that remains pending 270 days after receipt. The briefings would occur at the next closed meeting of the Board after the application remained pending more than 270 days.
As the Board case notes, the FDIC maintains timeframe goals for applications that can be acted on under delegated authority in the FDIC’s six regional offices. Those timeframe goals were established in 1996, were republished in 2018, are posted to the FDIC’s website, fdic.gov, and are measured from the date an application is considered substantially complete. Staff submits monthly reports to the Board of Directors of actions taken under delegated authority with respect to all types of applications, showing the number of days in process, based on the date the application is considered substantially complete.
The briefing requirement will be based on days from receipt and will cover all merger and deposit insurance applications, not just those that can be acted on under delegated authority. These briefings will help the Board understand the reasons that certain applications require longer than normal processing times.
The timeframe goals for applications that can be acted on under delegated authority are 60 days from acceptance of a substantially complete merger transaction and 120 days for a deposit insurance filing. During the period between the date of filing and date of acceptance of a filing as substantially complete, FDIC staff reviews the application materials and requests in writing any missing information or clarifications necessary to evaluate the applicable statutory factors. Even with the time that elapses between receipt and acceptance of a filing, a majority of deposit insurance and merger applications are decided well within 270 days from the date of receipt. The average number of days from receipt to action for the 866 merger applications received and acted on over the 5 years ended March 31, 2024, is 78 days; and the average number of days from receipt to action for the 95 deposit insurance applications received and acted on over the same timeframe is 209 days.
Again, I believe it will be helpful for staff to brief the Board on applications that are requiring longer than normal processing timeframes so that the Board can gain an understanding of the reasons. Accordingly, I support this proposal.