Despite strong opposition to its initial proposal to require larger banks to track deposits,he FDIC has now proposed to do so in a way it hopes will allay community-bank concerns and force insured depositories that pose the most risk to the FDIC to do so. Significant information-technology (IT) challenges would result, especially for banks holding large balances of deposits from brokers or custody banks holding trusts. However, the NPR now contains a process for seeking exemptions from the rule if IT costs can be shown to be prohibitive. The NPR also includes numerous other possible exemptions for which banks could apply to address prior comments, although it is clear that the agency’s goal is to require as many banks as possible to identify as much of their deposit base as they can to ensure that the FDIC has next-day access to information and customers receive ready access to their funds if an insured depository fails.  

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