RCFDK656: Banker's Bank Certification: Does the Reporting Institution Meet Both the Statutory Definition of a Banker's Bank and the Business Conduct Test Set Forth in FDIC Regulations?

Definition

If the reporting institution meets both of these criteria, it is a qualifying banker's bank and should answer 'Yes' to item 10 and complete items 10.a and 10.b. If the reporting institution does not meet both of these criteria, it should answer 'No' to item 10 and it should not complete items 10.a and 10.b. The definition of 'banker's bank' is set forth in 12 U.S.C. 24, which states that a banker's bank is an FDIC-insured bank where the stock of the bank or its parent holding company 'is owned exclusively (except to the extent directors' qualifying shares are required by law) by depository institutions or depository institution holding companies (as defined in section 1813 of this title)' and the bank or its parent holding 'company and all subsidiaries thereof are engaged exclusively in providing services to or for other depository institutions, their holding companies, and the officers, directors, and employees of such institutions and companies, and in providing correspondent banking services at the request of other depository institutions or their holding companies.' A bank that would otherwise meet the definition of a banker's bank, but has received funds from federal capital infusion programs (such as the Troubled Assets Relief Program and the Small Business Lending Fund), has stock owned by the FDIC as a result of bank failures, or has non-bank-owned stock resulting from equity compensation programs, is not excluded from the definition of a banker's bank for purposes of Schedule RC-O, item 10, provided the bank also meets the business conduct test. To meet the business conduct test, which is set forth in Section 327.5(b)(3) of the FDIC's regulations, a bank must conduct 50 percent or more of its business with entities other than its parent holding company or entities other than those controlled either directly or indirectly by its parent holding company. Control has the same meaning as in section 3(w)(5) of the Federal Deposit Insurance Act (12 U.S.C. 1813(w)(5)).

Source: Federal Reserve Micro Data Reference Manual (MDRM). The FFIEC call report instructions remain the authority on how to report the item.

Where RCFDK656 sits on the call report

The same item under other prefixes

Item K656 is also reported under these codes. Which banks file each one depends on the form they file.

Related

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