FDIC360 and Future Dated Holds

Posted By: YHWB

FDIC360 and Future Dated Holds - 07/16/21 06:00 PM

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.
Posted By: rlcarey

Re: FDIC360 and Future Dated Holds - 07/16/21 07:11 PM

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?
Posted By: YHWB

Re: FDIC360 and Future Dated Holds - 07/16/21 07:27 PM

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?
Posted By: rlcarey

Re: FDIC360 and Future Dated Holds - 07/16/21 08:25 PM

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?