A bank organizing group developing an application for deposit insurance need not give a specific address of the proposed institution’s main office but should “reasonably describe” the anticipated physical location in its application and in the required public notice, the Federal Deposit Insurance Corp. (FDIC) stated in a Financial Institution Letter (FIL) issued Monday.
The agency’s FIL-51-2019 also states that while the proposed chief executive officer must be identified at the time an insurance application is filed, other senior officers may be identified “later in the process,” the agency stated.
These two points, along with some further explanatory information, make up the content of the supplemental “Questions and Answers” transmitted with Monday’s FIL to complement the agency’s statement of policy on applications for deposit insurance, which took effect Oct. 1, 1998.
Regarding the main office location, the FIL and supplemental Q&As note that if an organizing group has not yet identified the specific address of the main office at the time of filing, the application should reasonably describe the anticipated physical location. The description, the agency notes, should be sufficient to enable the FDIC and all interested parties to understand the general location and geographic market of the proposed institution.
The required public notice should reflect the same location description as included in the application, the FDIC says.
More on the agency’s deposit insurance application process can be found in part 303 (subpart B) of the FDIC rules and regulations.