On August 10, the FDIC announced a new two-phase process for reviewing deposit insurance applications, which the agency said is intended to encourage new bank formation, accelerate review and improve application processing efficiency. Under the revised procedures, the FDIC will provide de novo applicants that satisfy relevant requirements with contingent authorization within 120 days after receiving an application, followed by a second phase of up to 12 months during which applicants will complete necessary organizational steps and provide additional information. The FDIC said the two-phase process will apply to all federal deposit insurance applications received after August 15.

The revised procedures encourage organizers to meet with FDIC staff and other applicable regulators before filing, and state that a dedicated FDIC case manager will be assigned during the pre-filing meeting. The FDIC also expects that applicants generally will be able to file simultaneously with the FDIC and the chartering authority, with the FDIC coordinating with the chartering authority throughout the application process to promote efficiency, avoid duplication and ensure timely action.

During the contingent authorization phase, FDIC staff will review the application and supporting materials, including the proposed business plan, financial projections, ownership and organizational structure, capital raise, proposed management and board information, insider and affiliate relationships, planned outsourcing, related regulatory applications and public notice. During the organizational phase, the FDIC said that it expects applicants to submit supplemental materials, including final governance documents, capital raise materials, key vendor agreements, office or branch information, risk management and compliance policies, CRA plans and other information relevant to the statutory factors, before the FDIC issues a final disposition. For approved applications, the FDIC will then schedule a pre-opening examination and issue a deposit insurance certificate.