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#2256814 - 07/16/21 06:00 PM FDIC360 and Future Dated Holds
YHWB Offline
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Should future dated holds be included in the bank's FDIC360 extract files. For example, a loan has a provision to automatically increase in value on December 31, 2021, and an automatic hold placed on a checking account for the amount of the increase.

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#2256823 - 07/16/21 07:11 PM Re: FDIC360 and Future Dated Holds YHWB
rlcarey Online
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rlcarey
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Galveston, TX
You might have to explain that a little more. What does an increase in the loan amount have to do with a hold placed on a deposit account?
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#2256827 - 07/16/21 07:27 PM Re: FDIC360 and Future Dated Holds YHWB
YHWB Offline
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In this example, the deposit account is being used as collateral for the loan. So the future dated hold would be tied to an increase in the LofC. Would a future dated hold be included in the FDIC360 extract?

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#2256830 - 07/16/21 08:25 PM Re: FDIC360 and Future Dated Holds YHWB
rlcarey Online
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rlcarey
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Galveston, TX
The FDIC Part 360 requirements are designed to be a snap shot in time at the time an institution fails. So I am confused why you are doing any sort of look forward?
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