993333

2021

ANNUAL 

PERFORMANCE 

PLAN
2

TABLE OF CONTENTS

CHAIRMAN’S MESSAGE 3

MISSION, VISION, AND VALUES 5

CREATING A SAFE, FAIR, AND INCLUSIVE WORK ENVIRONMENT 6

PROGRAM DESCRIPTIONS AND ANNUAL PERFORMANCE GOALS 7

Insurance Program 8

Supervision Program 27

Receivership Management Program 72

EFFECTIVE MANAGEMENT OF STRATEGIC RESOURCES 82

Introduction 83

Financial Resources Management 83

Human Capital Management 84

Management of Information Technology Resources 88

Enterprise Risk Management and Internal Controls 92

APPENDICES 93

Appendix A – Program Resource Requirements 94

Appendix B – Program Evaluation 95 

Appendix C – Interagency Relationships 96

Appendix D – External Factors 107

Appendix E – Organizational Chart 111
3

CHAIRMAN’S MESSAGE

I am pleased to present the Federal Deposit Insurance Corporation’s 2024 Annual Performance Plan. In 

accordance with the requirements of the Government Performance and Results Act (GPRA), as 

subsequently amended by the GPRA Modernization Act, it outlines the FDIC’s annual performance goals 

and targets for this year. The FDIC has successfully fulfilled its mission of maintaining stability and public 

confidence in the U.S. financial system for over 90 years. The importance of the FDIC’s mission was 

reaffirmed in 2023, when the FDIC took prompt action to manage the orderly resolution of five banks, 

including three large regional banks.

The FDIC’s success in fulfilling its mission has been primarily attributable to the dedication and hard work 

of its employees. Those employees deserve a workplace that makes each employee feel safe, valued, and 

respected. In response to recent news reports of sexual harassment within the FDIC, we are in the process 

of implementing a multi-faceted Action Plan, developed with input from our staff, to address identified 

workplace issues and ensure a safe, fair, and inclusive workplace. Additionally, the FDIC Board of Directors 

has established a Special Committee, led by Director Jonathan McKernan and Board Member Michael J. 

Hsu, Acting Comptroller of the Currency, to oversee an independent third-party review of our workplace 

culture by a respected outside law firm. The insights and recommendations from that review will be 

integrated into the Action Plan, as appropriate.

As of December 31, 2023, the FDIC insured more than 725 million accounts with more than $10.62 trillion in 

depositor funds at 4,596 institutions across the nation. The banking system continues to show resilience 

after a period of liquidity stress in early 2023 and ongoing economic and geopolitical uncertainties. The 

banking industry’s overall asset quality metrics remain favorable, liquidity is stable, and although net 

income declined modestly in 2023, it remains well above levels reported before the pandemic. However, 

continuing inflationary pressures, volatility in market interest rates, and deterioration in the industry’s 

commercial real estate portfolio contribute to an uncertain economic outlook that could pose significant 

downside risks to the banking industry. These issues, together with funding and earnings pressures, will be 

matters of close ongoing supervisory attention by the FDIC in 2024.
4

This annual performance plan identifies key areas of emphasis for the FDIC in 2024. These include 

enhanced prudential oversight of banks, particularly with respect to the management of capital, liquidity, 

and interest rate risks; implementation of supervisory changes in response to the lessons learned from 

bank failures in 2023; and initial collection of a special assessment to recover losses to the Deposit 

Insurance Fund (DIF) associated with the systemic risk determinations made in connection with two of the 

2023 bank failures. The FDIC will also advance rulemaking activities to strengthen capital requirements for 

large U.S. banking organizations through implementation of the Basel III framework, complete rulemaking 

to require large and complex financial institutions to hold long-term debt to facilitate their resolution in the 

event of financial distress, and begin planning for the implementation of the strengthened and modernized 

rule adopted last year to better achieve the objectives of the Community Reinvestment Act. Finally, the 

FDIC will continue to analyze the potential impact that emerging financial risks, such as crypto-related 

activities and climate change, could have on the safety and soundness of insured depository institutions 

(IDIs) and will pay increased attention to cybersecurity and other technology-related risks to IDIs.

The FDIC has been a symbol of trust for depositors in FDIC-insured financial institutions since 1933 and will 

carry that mission forward in 2024.

Martin J. Gruenberg

Chairman
5

MISSION, VISION, AND VALUES

MISSION

The Federal Deposit Insurance Corporation (FDIC) is an independent agency created by the Congress to 

maintain stability and public confidence in the nation’s financial system by:

• Insuring deposits,

• Examining and supervising financial institutions for safety and soundness and consumer 

protection,

• Making large, complex financial institutions resolvable, and

• Managing receiverships.

VISION

The FDIC is a recognized leader in promoting sound public policies; addressing risks in the nation’s financial 

system; and carrying out its insurance, supervisory, consumer protection, resolution planning, and 

receivership management responsibilities.

VALUES

The FDIC and its employees have a tradition of distinguished public service. Six core values guide us in 

accomplishing our mission:

Integrity We adhere to the highest ethical and professional standards.

Competence We are a highly skilled, dedicated, and diverse workforce that is empowered to 

achieve outstanding results.

Teamwork We communicate and collaborate effectively with one another and with other 

regulatory agencies.

Effectiveness We respond quickly and successfully to risks in insured depository institutions and 

the financial system.

Accountability We are accountable to each other and to our stakeholders to operate in a financially 

responsible and operationally effective manner.

Fairness We respect individual viewpoints and treat one another and our stakeholders with 

impartiality, dignity, and trust.
6

CREATING A SAFE, FAIR, AND INCLUSIVE WORK 

ENVIRONMENT

In November 2023, there were media reports about sexual harassment and misconduct at the FDIC. There 

is no higher priority at the FDIC than ensuring that every person at the agency feels safe, valued, and 

respected. The FDIC is bringing all resources of the agency to bear to address the problems that the reports 

identified. To that end, the FDIC published in December 2023 an Action Plan for a Safe, Fair, and Inclusive 

Work Environment. The Action Plan is available on the FDIC’s public website at

https://www.fdic.gov/about/diversity/pdf/action-plan-12-4-23-v1.pdf.

The Action Plan is organized around eight action areas:

• Support for Victims and Survivors;

• Prompt Investigation, Identification, and Correction of Current Problems;

• Repercussions for Harassers;

• Leadership Accountability;

• Policies, Procedures, and Operations Review and Enhancement;

• Training Programs;

• Communication and Outreach Strategy; and

• Cultural Transformation.

Within each action area, the FDIC identified specific initiatives to be pursued, each with a target completion 

date to faciltate ongoing monitoring of the progress being made in implementation of the plan. Most 

initiatives are projected to be completed in 2024.

Additionally, the FDIC Board established a Special Review Committee to direct and oversee an 

independent, third-party review of the FDIC’s workplace and culture. The review will focus on reports of 

sexual harassment and misconduct, as well as assessing the FDIC’s workplace culture, including any 

practices that might discourage or deter the reporting of, or appropriate resonses to, complaints of sexual 

harassment and misconduct. After the review is completed, its findings and recommendations will be 

integrated into the Action Plan, as appropriate. 
7

I. INSURANCE

II. SUPERVISION 

a. Risk Management

b. Consumer Compliance and Consumer Affairs

c. Resolution Planning

III. RECEIVERSHIP MANAGEMENT

PROGRAM DESCRIPTIONS AND ANNUAL PERFORMANCE 

GOALS
8

I. INSURANCE PROGRAM

Program Overview

Strategic Goal 1: FDIC-insured deposits are protected from loss without recourse to taxpayer 

funding.

Strategic Objective 1.1: The FDIC provides customers of failed insured depository institutions timely 

access to insured funds and financial services.

Annual Performance Goal 1.1-1 (page 13) Respond promptly to all IDI failures and related 

emerging issues.

Strategic Objective 1.2: The FDIC promptly identifies and responds to potential risks to the DIF.

Annual Performance Goal 1.2-1 (page 15) Disseminate data and analyses on issues and risks 

affecting the financial services industry to bankers, supervisors, the public, and other 

stakeholders on an ongoing basis.

Strategic Objective 1.3: The FDIC maintains a strong and adequately financed DIF.

Annual Performance Goal 1.3-1 (page 17) Monitor the status of the DIF reserve ratio and 

analyze the factors that affect fund growth. Adjust assessment rates, as necessary, to achieve a 

DIF reserve ratio of at least 1.35 percent by September 30, 2028.

Annual Performance Goal 1.3-2 (page 19) Expand and strengthen the FDIC’s participation and 

leadership role in supporting robust and effective deposit insurance programs, resolution 

strategies, and banking systems worldwide.

Annual Performance Goal 1.3-3 (page 21) Ensure timely consideration and efficient processing 

of de novo deposit insurance applications.

Strategic Objective 1.4: The FDIC resolves failed IDIs in the manner least costly to the DIF.

Annual Performance Goal 1.4-1 (page 22) Market failing IDIs to a targeted pool of qualified and 

interested potential bidders.

Strategic Objective 1.5: The FDIC provides the public and IDIs access to clear and accurate information 

about federal deposit insurance coverage.

Annual Performance Goal 1.5-1 (page 24) Provide educational information to IDIs and their 

customers to help them understand the rules for determining the amount of insurance coverage 

on deposit accounts.
9

Insurance Program Overview

One way the FDIC maintains stability and public confidence in the nation’s financial system is by 

providing deposit insurance. Through its industry- and consumer-awareness programs, the FDIC seeks 

to increase public awareness and understanding of deposit insurance rules and coverage. The FDIC 

takes steps to ensure that no person or organization makes false or misleading representations about 

deposit insurance, uses the FDIC’s name or logo in a manner that would imply that an uninsured 

financial product is insured or guaranteed by the FDIC, or knowingly misrepresents the extent or manner 

of deposit insurance. In addition, the FDIC (and other federal regulatory agencies) ensure that insured 

depository institutions (IDIs) accurately disclose products that are not insured by the FDIC. The FDIC also 

routinely provides depositors and financial institution staff with information regarding the insurance 

rules and limits that apply to specific types of deposit accounts. As of December 31, 2023, the FDIC 

insured more than 725 million accounts with more than $10.62 trillion in depositor funds at 4,596

institutions across the nation.

Before a prospective IDI can open for business, it must apply to the FDIC for federal deposit insurance. 

The FDIC evaluates each applicant’s potential risk to the DIF by assessing the adequacy of its proposed 

capital, future earnings potential, and the general character of its management. Before granting access 

to the federal deposit insurance system, the FDIC also considers the applicant’s plans for serving the 

deposit and lending needs of the community that the applicant plans to serve and obtains input from 

other regulatory authorities.

When an IDI fails and the FDIC is appointed as receiver, the FDIC ensures that the institution’s customers 

have prompt access to their insured deposits and other services. If an acquiring bank does not assume 

all of the failed institution’s deposits, the FDIC also typically provides access to a portion of uninsured 

deposits based on the expected return on the disposition of the assets of the failed institution. To keep 

pace with the evolving banking industry and maintain its readiness to protect insured depositors, the 

FDIC prepares and maintains contingency plans to respond promptly to a variety of IDI failure scenarios. 
10

The DIF balance was $121.8 billion as of December 31, 2023, $6.4 billion below the balance reported on 

December 31, 2022. The DIF reserve ratio, or the ratio of the fund balance to estimated insured deposits, 

stood at 1.15 percent as of December 31, 2023. The decline in the DIF balance was primarily driven by 

$18 billion in loss provision expenses associated with the failure of three large regional banks in early 

2023. This amount does not include the cost of protecting uninsured deposits pursuant to the systemic 

risk determination made in connection with the two bank failures that occurred in March 2023, as the 

FDIC is required by statute to recover those losses through one or more specal assessments. In 

November 2023, the FDIC Board adopted a final rule implementing the special assessment. The first 

collection for the special assessment will occur in June 2024. Under the final rule, the FDIC anticipated 

that the special assessment would be collected at an annual rate of approximately 13.4 basis points over 

eight quarterly assessment periods, beginning with the first quarterly assessment period of 2024. 

However, the special assessment amount and collection period may change as the result of periodic 

adjustments to the estimated loss pursuant to the systemic risk determination. Adjustments may be 

made as assets are sold, liabilities are satisfied, and receivership expenses are incurred, and if there are

corrective amendments to the amount of uninsured deposits reported for the December 31, 2022,

reporting period. Two additional institutions failed in the second half of 2023 at an estimated cost to the 

DIF of $69 million.

The DIF continues to operate under the Restoration Plan adopted in September 2020, following 

extraordinary growth in insured deposits, and later amended in October 2022, to restore the DIF reserve 

ratio to at least 1.35 percent within eight years, as required by statute.

1

 While the DIF balance declined in 

2023, the FDIC’s most recent semiannual update concluded that the reserve ratio remains on track to 

reach the statutory minimum ahead of the deadline, although the precise timing is unknown and 

depends on a number of factors, including insured deposit growth and future bank failures. In 2023, 

insured deposits grew by 3.6 percent, below the long-term average rate of 4.5 percent.2 The number of 

problem banks was 52 as of December 31, 2023, well within historical levels.

 1 12 U.S.C. 1817(b)(3)(B) and (E) 2 Long-term average rate based on data from 2000 to 2019.
11

The table below depicts the strategic goal, strategic objectives, and annual performance goals for the 

Insurance Program.

Strategic Goal Strategic Objectives Annual Performance Goals

FDIC-insured 

deposits are 

protected from 

loss without 

recourse to 

taxpayer 

funding.

The FDIC provides 

customers of 

failed insured 

depository 

institutions (IDIs) 

timely access to 

insured funds and 

financial services.

Respond promptly to all IDI failures 

and related emerging issues. (1.1-1)

The FDIC promptly 

identifies and 

responds to 

potential risks to 

the DIF.

Disseminate data and analyses on 

issues and risks affecting the 

financial services industry to 

bankers, supervisors, the public, 

and other stakeholders on an 

ongoing basis. (1.2-1)

The FDIC 

maintains a strong 

and adequately 

financed DIF.

Monitor the status of the DIF 

reserve ratio and analyze the 

factors that affect fund growth. 

Adjust assessment rates, as 

necessary, to achieve a DIF reserve 

ratio of at least 1.35 percent by 

September 30, 2028. (1.3-1)

Expand and strengthen the FDIC’s 

participation and leadership role in 

supporting robust and effective 

deposit insurance programs, 

resolution strategies, and banking 

systems worldwide. (1.3-2)

Ensure timely consideration and 

efficient processing of de novo

deposit insurance applications. 

(1.3-3)

The FDIC resolves 

failed IDIs in the 

manner least 

costly to the DIF.

Market failing IDIs to a targeted 

pool of qualified and interested 

potential bidders. (1.4-1)
12

The FDIC provides 

the public and IDIs 

access to clear and 

accurate 

information about 

federal deposit 

insurance 

coverage.

Provide educational information to 

IDIs and their customers to help 

them understand the rules for 

determining the amount of 

insurance coverage on deposit 

accounts. (1.5-1)
13

STRATEGIC GOAL 1:

FDIC-insured deposits are protected from loss without recourse to taxpayer funding.

STRATEGIC OBJECTIVE 1.1

The FDIC provides customers of failed IDIs timely access to insured funds and financial services.

Annual Performance Goal 1.1-1

Respond promptly to all IDI failures and related emerging issues.

Indicators and Targets

1. Number of business days after an IDI failure that depositors first have access toinsured funds

• Depositors have access to insured funds within one business day if the failure occurs 

on a Friday.

• Depositors have access to insured funds within two business days if the failure

occurs on any other day of the week.

2. Insured depositor losses resulting from an IDIfailure

• Depositors do not incur any losses on insured deposits.

• No appropriated funds are required to pay insured depositors.

Means and Strategies

Operational Processes (initiatives and strategies): In typical cases, when an IDI is identified as 

one that could potentially fail, the FDIC develops an operational plan to handle its resolution. 

The resolution process begins with an assessment of the IDI’s assets and liabilities. An 

information package is prepared as a marketing tool for qualified bidders that are interested in 

acquiring the failing IDI. After conducting due diligence, bidders submit bids that are evaluated 

and compared to the cost of liquidation to determine the least-costly resolution.
14

If the federal or state chartering authority chooses to close the institution, the FDIC is named receiver, 

allowing it to take control of the failed IDI and, if necessary, determine which deposits are insured. 

If a buyer is found, the FDIC works with the assuming institution to transfer purchased assets, along with 

either all deposits or only insured deposits, as quickly as possible. If a buyer is not found during the 

resolution process, insured balances are disbursed directly to the depositors of the failed IDI and all 

assets remain in the receivership. In either case, the insured depositors are provided access to their 

deposit accounts within one or two business days.

Human Resources (staffing and training): For 2024, the FDIC’s Division of Resolutions and Receiverships 

has authorized staffing of 426 permanent employees dedicated to handling the failure of IDIs and the 

management of ensuing receiverships. This permanent workforce is currently supplemented by nonpermanent employees to handle temporarily elevated workload levels. The number of open 

receiverships continues to decline, but the volume of assets under management increased substantially 

as a result of the bank failures in the spring of 2023.

Information Technology: Technology is critical to making deposit insurance determinations and 

payments efficiently. The FDIC uses the Claims Administration System (CAS) to identify depositors’ 

insured and uninsured funds in failing IDIs. For every failing IDI, CAS is used prior to failure to estimate 

the amount of uninsured deposits for use in the least-cost test. When an insured deposit transaction or a 

payout is the least-costly resolution, CAS is also used to determine the amount of insured deposits. CAS 

is the system of record for the deposits of the failed IDI and subsequent claims processing and tracking.

Verification and Validation

If insured deposits are transferred to an assuming IDI, the number of business days before depositors 

have access to their insured funds is verified by comparing the date of failure to the date that the 

assuming IDI opens for business and makes insured funds available to the failed IDI’s depositors. For a 

deposit payout, the measure of the number of business days to funds availability is verified by 

comparing the date of failure with the date that insured funds are disbursed to depositors.
15

2023 Performance Results

The FDIC successfully met the performance targets for this annual performance goal in 2023. This 

annual performance goal and its associated performance indicators and targets are unchanged for 2024.

STRATEGIC OBJECTIVE 1.2

The FDIC promptly identifies and responds to potential risks to the DIF.

Annual Performance Goal 1.2-1

Disseminate data and analyses on issues and risks affecting the financial services industry to bankers, 

supervisors, the public, and other stakeholders on an ongoing basis.

Indicator and Targets

1. Scope and timeliness of information dissemination on identified or potential issues and risks

• Disseminate results of research and analyses in a timely manner through regular 

publications, ad hoc reports, and other means.

• Undertake industry outreach activities, as needed, to inform bankers and other

stakeholders about current trends, concerns, available resources, and FDIC 

performance metrics.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC maintains a robust and 

comprehensive research and publications program that focuses on issues and topics of 

importance to the banking industry. Much of this research is conducted in collaboration with 

the academic community through the FDIC’s Center for Financial Research (CFR). Research 

findings are disseminated through meetings of the Advisory Committee on Community Banking 

(CBAC) and the Advisory Committee on Economic Inclusion (ComE-IN), CFR Working Papers, 
16

FDIC Staff Studies, articles in professional journals and other publications, and presentations at 

conferences and other events. The FDIC also disseminates information and analyses on industry 

risks through periodic reports and publications (e.g., the FDIC Quarterly Banking Profile and the 

FDIC Quarterly), Financial Institution Letters, participation in industry events, and other 

outreach activities.

The FDIC conducts outreach sessions several times each year across the country. In addition, FDIC 

employees regularly attend conferences and meet with industry analysts and trade groups to exchange 

views and analyses. FDIC employees also present Directors’ College outreach sessions to bank board 

members. During these sessions, FDIC employees share information with bank directors on current 

risks, new regulations, and emerging issues. Local FDIC offices nationwide also conduct banker 

roundtable events that provide opportunities for bankers to receive information and raise questions 

about laws, regulations, or emerging risks.

Human Resources (staffing and training): The FDIC employs economists, financial analysts, and other 

staff members who monitor risks within the banking industry and communicate those risks to FDIC 

management, other regulators, the industry, the public, and other stakeholders through a variety of 

mediums. In addition, FDIC managers, examiners, and other staff located throughout the country 

conduct banker outreach sessions as a collateral duty.

Information Technology: The FDIC’s public website (https://www.fdic.gov) is a centralized source for 

FDIC research and analysis on potential areas of risk that is available to the industry, the public, and 

other regulators. Databases and reports provide comprehensive financial and structural information 

about every FDIC-insured institution. These data assets are freely available, including through opensource formatted downloads and modern data retrieval methods such as application programming 

interfaces, to provide easy access to financial institution information for all users of the data, including 

financial institutions, bank regulators, and the public.
17

Verification and Validation

Timely analyses of banking industry risks are included in regular publications or issued as ad hoc 

reports. Industry outreach activities aimed at the banking community and industry trade groups 

promote discussion of current trends and concerns and inform bankers about available FDIC resources. 

Publications and outreach events are documented through established management reporting 

processes.

2023 Performance Results

The FDIC successfully met the performance targets for this annual performance goal in 2023. This 

annual performance goal and its associated performance indicator and targets are unchanged for 2024.

STRATEGIC OBJECTIVE 1.3

The FDIC maintains a strong and adequately financed DIF.

Annual Performance Goal 1.3-1

Monitor the status of the DIF reserve ratio and analyze the factors that affect fund growth. Adjust 

assessment rates, as necessary, to achieve a DIF reserve ratio of at least 1.35 percent by September 30, 

2028.

Indicators and Targets

1. Updated fund balance projections and recommended changes to assessmentrates

• Provide updated fund balance projections to the FDIC Board of Directors

semiannually. 

• Recommend changes to deposit insurance assessment rates to the FDIC Board of 

Directors, as necessary.
18

2. Progress updates and adjustments to the Restoration Plan 

• Provide progress reports to the FDIC Board of Directors semiannually, in accordance 

with the Restoration Plan.

• Implement the special assessment to recover the costs incurred by the DIF due to 

the systemic risk exceptions made to protect uninsured deposits in banks that failed 

in March 2023.

• Collect the special assessment beginning with the first quarterly assessment period 

in 2024 (January 1 to March 31).

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC’s Financial Risk Committee (FRC) 

recommends to the Chief Financial Officer a DIF contingent loss reserve for anticipated failures of open 

banks. The FRC regularly reviews adverse events to identify lessons or implications for monitoring and 

addressing risks in these banks and consults with the other federal banking agencies in its deliberations. 

The FDIC also maintains and, as necessary, enhances models that forecast failures, failure resolution 

costs, assessment revenue, investment revenue, operating expenses, and insured deposit growth in 

order to update the outlook for the insurance fund balance and reserve ratio. The FDIC also considers 

the effects of monetary policy, economic growth, and the personal savings rate on the banking industry 

and insured deposits. The FDIC continues to enhance the techniques and methodologies used to 

analyze the nature of risk exposure, including scenario analysis and stress testing.

Human Resources (staffing and training): FDIC staff perform the analytical work associated with deposit 

insurance pricing and the analysis of fund adequacy. 

Information Technology: The Risk-Related Premium System (RRPS) calculates the assessment rates that 

financial institutions are assessed for deposit insurance. The FDIC evaluates whether updates to RRPS 

are necessary to ensure accurate pricing and information are included in institution invoices.
19

Verification and Validation

A security review of RRPS is conducted annually to ensure that the system identifies higher-risk 

institutions and appropriately assesses higher insurance premiums. In addition, the Government 

Accountability Office reviews annually the methodology used to determine the contingent loss reserve.

2023 Performance Results

The FDIC successfully met the performance targets for this annual performance goal in 2023. This 

annual performance goal and its associated performance indicators and targets have been updated for 

2024. 

Annual Performance Goal 1.3-2

Expand and strengthen the FDIC’s participation and leadership role in supporting robust and effective 

deposit insurance programs, resolution strategies, and banking systems worldwide.

Indicator and Targets

1. Activities to expand and strengthen the FDIC’s engagement with strategically important foreign 

jurisdictions and its participation in and leadership of key international organizations and 

associations

• Engage with strategically important jurisdictions and organizations on international 

financial safety net issues.

• Provide training and technical assistance to promote sound deposit insurance and effective 

bank supervision and resolution practices.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC provides technical guidance, training, and 

information to international banking, deposit insurance, and resolution organizations.
20

This is achieved through the FDIC’s relationships with international financial institutions and regulatory 

agencies, and its leadership roles and participation in the International Association of Deposit Insurers 

(IADI), the Financial Stability Board (FSB), and the Association of Supervisors of Banks of the Americas 

(ASBA). The FDIC also supports visits and provides training and technical assistance for foreign 

counterparts in order to strengthen financial institution supervision and regulation.

The FDIC provides leadership on the executive boards and several committees of IADI and ASBA. In 

2024, the Deputy to the Chairman for Financial Stability will serve as the FDIC representative on IADI’s 

Executive Council and as the chair of the Training and Technical Assistance Council Committee. The 

FDIC also chairs IADI’s Capacity Building Technical Committee.

In 2024, the FDIC will continue to serve as the representative for the North America region on the ASBA 

Board of Directors. 

Human Resources (staffing and training): Available resources include FDIC staff dedicated to promoting 

the adoption of sound bank supervision, resolution, and deposit insurance principles and coordinating 

the FDIC’s global outreach and technical assistance programs, supplemented by subject matter experts 

across the FDIC. In 2024, training will expand the FDIC’s staff expertise in evaluating the compliance of 

deposit insurance systems with IADI’s Core Principles.

Information Technology: Information about the FDIC’s international programs, such as technical 

assistance, foreign visitors, and international leadership development programs, as well as associations 

with international bodies, including IADI and ASBA, is communicated through the FDIC’s public website 

(https://www.fdic.gov).

Verification and Validation

Progress in meeting this annual goal is reported through established management reporting processes. 

Quarterly reports document trends in the number of foreign visitors, foreign officials trained, technical 

assistance missions, and FDIC participation and leadership in key international organizations.
21

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and its associated performance indicator and targets have been updated for 2024.

Annual Performance Goal 1.3-3

Ensure timely consideration and efficient processing of de novo deposit insurance applications.

Indicator and Target

1. Timeliness of review of draft community bank deposit insurance applications

• Provide feedback on 75 percent of draft community bank deposit insurance 

applications no later than 60 days after receipt to facilitate the ultimate 

submission of a formal application.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC seeks to ensure its application process is

clear and efficient and that deposit insurance applications are considered in a timely manner and are 

evaluated in accordance with statutory factors. Proposed depository institutions apply for federal 

deposit insurance by filing an Interagency Charter and Federal Deposit Insurance Application with the 

appropriate FDIC regional office. 

Applicants have the option of submitting a draft application in advance of a formal filing. The draft 

review process is designed to be collaborative. The FDIC engages in a dialogue with the organizers and 

provides feedback that may occur in stages.

The FDIC attempts to provide interim feedback to the organizers no later than 30 days after receiving a 

draft proposal, and to communicate overall feedback within 60 days of receipt.
22

The timeframe may vary depending on the attributes of a given proposal and may extend beyond the 60-

day goal if modifications to the draft proposal are submitted (the 60-day target timeframe re-starts upon 

receipt of a modified proposal).

Human Resources (staffing and training): Available resources include case managers, who evaluate 

applications; application subject matter experts in each regional office and in Washington, who are 

available to provide any needed support; managers and supervisors in regional offices and Washington; 

and legal advisors. 

Information Technology: Information about the FDIC’s deposit insurance application processes 

is available on the FDIC’s public website at 

https://www.fdic.gov/transparency/bankapplications.html.

Verification and Validation 

Progress in meeting the goal is reported through established management reporting processes. 

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and its associated performance indicator and target are unchanged for 2024. 

STRATEGIC OBJECTIVE 1.4

The FDIC resolves failed IDIs in the manner least costly to the DIF.

Annual Performance Goal 1.4-1 

Market failing IDIs to a targeted pool of qualified and interested potential bidders. 
23

Indicator and Target

1. Scope of qualified and interested bidders solicited

• Contact a targeted pool of qualified and interested bidders.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC markets the deposits and assets of failing IDIs

to a targeted pool of qualified and interested potential bidders to encourage as much competition as 

possible. An inventory is maintained of qualified financial institutions that may be interested in bidding 

for a failing institution. When preparing a list of potential bidders for a failing IDI, consideration is given 

to the institution’s geographic location, competitive environment, minority-owned status, financial 

condition, asset size, capital level, and regulatory ratings. Insured deposit acquisitions must be made by 

another IDI, while assets and other liabilities may be offered to other bidders. An IDI’s primary federal 

regulator may add or exclude an IDI from the bidder’s list and must approve the selecton of the winning 

bidder. Potential bidders are given the opportunity to perform due diligence to assess the failing IDI’s 

assets and liabilities before determining whether to submit bids.

Human Resources (staffing and training): The marketing of failing IDIs is carried out primarily by existing 

FDIC personnel. Staffing requirements are continually assessed within the context of current and 

projected workload to ensure that the FDIC is appropriately staffed. The FDIC may utilize contractor 

support, non-permanent employees, and employees temporarily assigned from other divisions to meet 

heightened workload demands and mission responsibilities in this area.

Information Technology: The Resolution Information Tracking Application (RITA) provides a 

comprehensive source of information for the marketing and sale of failing IDIs, including managing bid 

list criteria for each prospective resolution transaction and the list of qualified potential bidders. In 

addition to other data, RITA contains information on the valuation, marketing strategies, and sale of 

assets to an acquirer at the time of resolution.
24

Verification and Validation

Progress in meeting this annual performance goal is tracked in RITA and reported through established 

management reporting processes. 

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and its associated performance indicator and target are unchanged for 2024.

STRATEGIC OBJECTIVE 1.5

The FDIC provides the public and IDIs access to clear and accurate information about federal deposit 

insurance coverage.

Annual Performance Goal 1.5-1

Provide educational information to IDIs and their customers to help them understand the rules for 

determining the amount of insurance coverage on deposit accounts.

Indicators and Targets

1. Timeliness of responses to deposit insurance coverage inquiries

• Respond within two weeks to 95 percent of written inquiries from consumers and 

bankers about FDIC deposit insurance coverage.

2. Initiatives to increase public awareness of deposit insurance coveragechanges

• Conduct at least four virtual or in-person seminars for bankers on deposit insurance

coverage.
25

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC uses various methods to educate IDI

employees and depositors about deposit insurance coverage.

The FDIC administers a public education program that includes developing and distributing a wide range 

of written materials, videos, electronic calculators, and other tools to help consumers and bank 

employees understand how deposit insurance works. In addition, the FDIC provides training to and 

conducts seminars for bank employees and encourages the dissemination of educational information 

through the banking industry and the media. 

The FDIC also: 

• Operates a Contact Center3 to answer questions about FDIC deposit insurance coverage. 

The FDIC Contact Center is staffed by contractors who are trained to provide answers to 

many different questions about deposit insurance coverage. Complex or unique issues, or 

those requiring additional analysis and review, are referred by the Contact Center to FDIC 

subject matter experts in the Deposit Insurance (DI) section of the National Center for 

Consumer and Depositor Assistance (NCDA), who specialize in deposit insurance issues 

and can research the issues and respond appropriately. 

• Maintains educational and informational resources on its public website at 

https://www.fdic.gov/resources/deposit-insurance. 

• Publishes articles on deposit insurance coverage in the FDIC Consumer News (a monthly 

newsletter for consumers published by the FDIC).

• Works to raise public awareness of deposit insurance coverage through the national and 

regional news media, including social media. 

 

3 FDIC’s toll-free phone number is 877-ASK-FDIC, and the Information and Support Center is available at 

https://www.fdic.gov/contact/. 
26

In 2024, the FDIC will implement a new regulation adopted by its Board of Directors in December 2023, 

on the official FDIC sign and advertising statement that clarified rules regarding false advertising, 

misrepresentation about deposit insurance, and misuse of the FDIC name or logo.

The FDIC will also continue its national “Know Your Risk, Protect Your Money” campaign to increase 

public awareness of deposit insurance and how it protects depositors’ money in the event of a bank 

failure.

Human Resources (staffing and training): The FDIC has a dedicated staff of specialists and contractors 

who respond to telephone and written inquiries from consumers and bankers about deposit insurance 

coverage. The FDIC Contact Center is also supported by a dedicated staff of subject matter experts who 

provide responses to inquiries about complex deposit insurance issues. 

Information Technology: The FDIC tracks the receipt of, and response to, written inquiries through the

Enterprise Public Inquiry and Complaint System (EPIC). The FDIC also provides the Electronic Deposit 

Insurance Estimator (EDIE), which consumers and bankers can use to estimate deposit insurance 

coverage, on its public website (https://edie.fdic.gov/index.html). 

Verification and Validation

Progress in meeting the performance targets for this goal will be tracked through EPIC and established 

management reporting processes.

2023 Performance Results

The FDIC successfully met the performance targets for this annual performance goal in 2023. This 

annual performance goal and its associated performance indicators and targets are unchanged for 2024. 
27

II. SUPERVISION PROGRAM

Program Overview

Strategic Goal 2: FDIC-insured institutions are safe and sound.

Strategic Objective 2.1: The FDIC exercises its statutory authority, in cooperation with other primary 

federal regulators and state agencies, to promote safe and sound practices at FDIC-insured depository 

institutions, including appropriate risk management.

Annual Performance Goal 2.1-1 (page 42) Conduct on-site risk management examinations to 

assess the overall financial condition, management practices and policies, and compliance with 

applicable laws and regulations of FDIC-supervised depository institutions. When problems are 

identified, promptly implement appropriate corrective programs and follow up to determine 

whether identified problems are corrected and take other actions as appropriate.

Annual Performance Goal 2.1-2 (page 45) Assist in protecting the infrastructure of the U.S. 

banking system against terrorist financing, money laundering, and other financial crimes.

Annual Performance Goal 2.1-3 (page 46) Ensure that risk-based capital standards sufficiently 

capture risk, remain robust, and promote banks’ resilience under stress.

Annual Performance Goal 2.1-4 (page 48) Implement strategies to promote enhanced 

cybersecurity and business continuity within the banking industry.

Annual Performance Goal 2.1-5 (page 50) Update rules, regulations, and other guidance to 

promote the safety and soundness of the financial system.

Annual Performance Goal 2.1-6 (page 54) Increase engagement and collaboration to preserve 

and promote FDIC-insured minority depository institutions (MDIs) and mission-driven institutions.

Strategic Goal 3: FDIC-supervised institutions are compliant with federal consumer protection 

laws, including fair lending laws, and the Community Reinvestment Act (CRA).

Strategic Objective 3.1: The FDIC supervises institutions for compliance with applicable federal 

consumer protection laws, including fair lending laws; the law against unfair and deceptive practices; and 

the CRA.

Annual Performance Goal 3.1-1 (page 57) Conduct on-site CRA and consumer compliance 

examinations to assess compliance with applicable laws and regulations by FDIC- supervised 

institutions. When violations are identified, promptly implement appropriate corrective 

programs/actions and follow up until identified problems are fully corrected.
28

Strategic Objective 3.2: The FDIC provides clear and accessible information to consumers about their 

rights under federal consumer protection and fair lending laws and regulations, including applicable 

disclosures.

Annual Performance Goal 3.2-1 (page 59) Effectively investigate and respond to written 

consumer complaints and inquiries about FDIC-supervised financial institutions.

Strategic Objective 3.3: The FDIC encourages IDIs to offer affordable checking and savings accounts and 

loan products that meet the needs of consumers.

Annual Performance Goal 3.3-1 (page 61) Promote economic inclusion and access to 

responsible financial services through supervisory, research, policy, and consumer/community 

affairs initiatives.

Strategic Goal 4: Large, complex financial institutions are resolvable in an orderly manner.

Strategic Objective 4.1: Large, complex financial institutions are resolvable under the bankruptcy code 

or, for covered IDIs, the FDI Act, as applicable.

Annual Performance Goal 4.1-1 (page 65) Identify and address risks in LCFIs, including those 

designated as systemically important.

Strategic Objective 4.2: In the event of the failure of a large, complex financial institution, the FDIC 

carries out the resolution in an orderly manner in accordance with statutory mandates.

Annual Performance Goal 4.2-1 (page 68) Continue to build the FDIC’s operational readiness to 

administer the resolution of LCFIs, including those designated as systemically important.
29

Supervision Program Overview

Another way the FDIC promotes stability and public confidence in the nation’s financial system is 

through its Supervision Program, which promotes the safety and soundness of IDIs, protects 

consumers, and promotes community development and investment initiatives by FDICsupervised institutions.

Risk Management

The FDIC is the primary federal regulator for state-chartered banks and savings associations that are not 

members of the Federal Reserve System, generally known as state nonmember banks and state-chartered 

savings associations. This includes state-licensed insured branches of foreign banks. As insurer, the FDIC 

also has special back-up examination authority for state member banks that are supervised by the Board 

of Governors of the Federal Reserve System (FRB) and national banks and federal savings associations

that are supervised by the Office of the Comptroller of the Currency (OCC), including the largest, global 

systemically important banks (GSIBs). The FDIC’s roles as insurer and primary regulator are 

complementary, and many activities undertaken by the FDIC support both the insurance and supervision 

programs. The FDIC monitors and evaluates the potential risks at all insured institutions, including those 

for which it is not the primary federal regulator, through examinations, off-site monitoring tools, 

participation in examinations conducted by other federal regulators, and inter-divisional risk monitoring 

activities.

As the primary federal regulator of all insured state nonmember banks and state-chartered savings 

associations, the FDIC performs periodic risk management examinations to assess institutions’ overall 

financial condition, risk management policies and practices, and compliance with applicable laws and 

regulations. The FDIC also performs Anti-Money Laundering (AML) / Countering the Financing of 

Terrorism (CFT) and information technology (IT) reviews at each risk management examination and, when 

applicable, conducts reviews of trust, registered transfer agent, municipal securities dealer, and 

government security dealer activities.
30

Through the examination process, the FDIC also assesses the adequacy of an institution’s management 

and effectiveness of its internal control systems in identifying and controlling risks and how well an 

institution is managing the risks associated with its particular business model. Banks engaged in 

traditional, non-complex activities receive periodic, point-in-time safety and soundness examinations that 

are carried out over a few weeks, while those engaged in novel or more complex activities and those with 

complex operations are subject to continuous safety-and-soundness examinations carried out through 

targeted reviews during the course of an examination cycle.

Approximately 98 percent of all FDIC-supervised institutions are examined under the point-in-time 

examination process. Risk management point-in-time examinations are conducted every 12 to 18 

months, generally on an alternating basis with the appropriate state banking authority. Risk management 

continuous examinations are conducted throughout an annual examination cycle by a dedicated team of 

examiners working jointly with the appropriate state banking department. The examination team 

produces examination findings throughout the cycle after the completion of various targeted reviews of 

specific risk areas and a roll-up report of examination at the end of the annual examination cycle.

The findings of examinations are shared with an institution’s management and Board of Directors in the 

Report of Examination. If unsafe or unsound practices or conditions or breaches of fiduciary duty are 

identified through the examination process, the FDIC promptly takes appropriate supervisory action. 

Formal and informal enforcement actions may be taken to address an institution’s unsafe or unsound 

practices or conditions, as well as an individual’s actionable misconduct. These enforcement actions 

remain in place until the condition is remedied and the FDIC determines that the enforcement action may 

be amended or terminated.

The FDIC uses off-site monitoring programs to supplement and guide the examination process. Off-site 

monitoring programs can provide an early indication that an institution’s risk profile may be changing. 

The FDIC has developed a number of off-site monitoring tools using key data from institutions’ quarterly 

Reports of Condition and Income (i.e., Call Reports) to identify institutions that are experiencing rapid 

loan growth or reporting unusual levels or trends in problem loans, investment activities, funding 

strategies, earnings structure, or capital levels that merit further review.
31

Off-site monitoring for banks with total assets greater than $10 billion includes the quarterly Large 

Insured Depository Institution (LIDI) Program, which remains the primary instrument for off-site 

monitoring of the largest institutions supervised by the FDIC. The LIDI Program provides a comprehensive 

process to standardize data capture and reporting for large and complex institutions nationwide, allowing 

for quantitative and qualitative risk analysis. In 2023, the LIDI Program covered 118 institutions with total 

assets of $4.4 trillion. 

The three large regional bank failures in early 2023 highlighted a number of risks within the current 

banking environment that require increased supervisory attention. These include rapid growth, interest 

rate risk management, unrealized losses on loans and securities, concentrations of uninsured deposits, 

and potential liquidity risks. In addition, those failures underlined the importance of promptly escalating 

issues when banks are not responsive to supervisory concerns and, when necessary, compelling banks to 

comply with reasonable supervisory direction to address those issues. In 2024, the FDIC expects to 

continue its efforts to address the risks and risk management principles highlighted in 2023 and the 

lessons learned from the 2023 bank failures.

In that regard, the FDIC completed a comprehensive review of the LIDI Program during 2023 and 

implemented changes to refine its risk focus for the growing number of large institutions. The FDIC will 

implement further updates in 2024. Like its predecessor, the updated program, called LIDI-RADAR (Risk 

Assessment: Direction, Analysis, Reporting), focuses on institutions’ potential vulnerabilities to asset, 

funding, and operational stresses, and evaluates the risk posed by a large institution to the DIF. Planned 

2024 updates will incorporate lessons learned from the failure of three regional banks in 2023, heighten 

the focus on key risks, and more effectively link off-site monitoring with supervisory actions, adjustments 

to insurance assessments, and resolution planning readiness. The changes will also improve the riskfocused approach used in allocating resources to higher-risk institutions and will implement framework 

changes intended to make emerging risks more transparent.

In its supervisory role, the FDIC also acts on applications from IDIs to undertake certain transactions or 

engage in new or expanded business activities. In reviewing these applications, the FDIC evaluates the 

statutory factors relevant to each application.
32

Generally, depending on the type of application, these factors may pertain to capital adequacy, 

management, financial resources, convenience and the needs of the community to be served, and the risk 

to the DIF. Consistent with the relevant statutory factors, the FDIC’s evaluations also consider an 

institution’s compliance with consumer protection and fair lending laws and regulations, as well as 

performance under the Community Reinvestment Act (CRA).

Large, Complex Financial Institutions (LCFIs)

As both an extension of its supervision responsibilities and pursuant to its statutory role as a resolution 

authority, the FDIC is responsible for monitoring and assessing risks posed by, and planning for the 

resolution of, LCFIs under authority derived from the Dodd-Frank Wall Street Reform and Consumer 

Protection Act (Dodd-Frank Act) and the Federal Deposit Insurance Act (FDI Act). The FDIC considers LCFIs 

to be those IDIs with over $100 billion in total assets, as well as other systemically important financial 

companies designated by the Financial Stability Oversight Council (FSOC).

In carrying out these responsibilities, the FDIC performs the following tasks:

• Identifies and evaluates risks to U.S. financial stability related to the potential failure 

of an LCFI, and assesses the efforts of LCFIs to mitigate those risks, including acting as 

primary federal supervisor for those state-chartered LCFIs that are not members of 

the Federal Reserve System.

• Assesses resolution plans submitted by certain LCFIs to reorganize or liquidate under 

the U.S. Bankruptcy Code in the event of material financial distress or failure.

• Prepares to conduct an orderly liquidation of such institutions, if necessary, under the 

applicable resolution regime.

Ongoing risk analysis and monitoring is conducted by resident FDIC teams at certain 

LCFIs and off-site analytical teams composed of quantitative experts and complex financial 

institution specialists with resolution and supervision backgrounds. The resident on-site teams 

perform firm-specific independent analyses focused on key and emerging risks that increase, or 

may potentially increase, the vulnerability of the firm.
33

The FDIC’s off-site teams develop holistic views of key and emerging risks throughout the LCFI 

portfolio and the financial industry by analyzing industry and market conditions and trends and 

participating in supervisory examinations to support individual institution monitoring and the 

consideration of broader policy issues.

The FDIC has implemented, and continues to expand, its off-site monitoring capabilities for LCFIs. 

It maintains an individual risk profile and risk assessment for each LCFI (including large foreign 

banking organizations) that is based on an evaluation of key metrics that serve as important 

indicators of overall firm-specific risk. This risk assessment supports the identification of 

emerging and outsized risks within individual firms and the prioritization of supervisory and 

monitoring activities.

The FDIC also engages in resolution planning for IDIs. For large, complex IDIs, resolution planning 

is conducted pursuant to Section 360.10 of the FDIC Rules and Regulations (the “IDI rule”).

The IDI rule requires covered IDIs to submit resolution plans that would allow the FDIC, as 

receiver, to resolve the institution under the FDI Act in an orderly manner that enables prompt 

access to insured deposits, maximizes the return from the sale or disposition of the failed IDI’s 

assets, and minimizes losses realized by creditors (including the DIF) in the resolution.

In addition, the FDIC is jointly responsible with the FRB for reviewing the resolution plans filed by 

bank holding companies (BHCs) and FSOC-designated non-bank financial companies under 

Section 165(d) of the Dodd-Frank Act to ensure that each provides a plan for the reorganization or 

liquidation of the firm under the U.S. Bankruptcy Code in a manner that substantially mitigates 

the risk that the failure of the firm would have serious adverse effects on financial stability in the 

United States. Each resolution plan, commonly known as a “living will,” submitted under Section 

165(d) must present a credible strategy for the firm’s rapid and orderly resolution under the Code 

in the event of its material financial distress or failure.
34

Under Title II of the Dodd-Frank Act, the FDIC may also be called upon to carry out the orderly 

liquidation of a financial company whose material financial distress or failure is determined to 

pose systemic risk to U.S. financial stability, whether the financial company is a GSIB, a 

Systemically Important Financial Market Utility (SIFMU), or any other type of financial company 

that may pose such a risk. However, the invocation of the FDIC’s orderly liquidation authority 

may only occur in circumstances when it is determined that resolution under the U.S. Bankruptcy 

Code (or other applicable resolution framework) would threaten U.S. financial stability. The FDIC 

pursues planning and operational readiness initiatives on an ongoing basis to bolster its ability to 

administer the resolution of LCFIs using the applicable authority under the FDI Act or Title II of the 

Dodd-Frank Act.

In 2024, the FDIC will pursue rulemaking to strengthen resolution planning requirements for IDIs 

and to require large banks to maintain long-term debt to improve financial stability and facilitate 

their resolution in the event of failure. The FDIC will also provide guidance to help certain large 

bank holding companies further develop their Dodd-Frank Act Title I resolution plans.

Consumer Compliance and Consumer Affairs

The FDIC’s consumer compliance examination program promotes compliance with federal consumer 

protection laws, fair lending statutes (e.g., the Equal Credit Opportunity Act and the Fair Housing Act), the 

CRA, and the regulations that implement these laws. The purpose of consumer compliance examinations 

is to assess the quality of an FDIC-supervised IDI’s compliance management system, review an 

institution’s compliance with relevant laws and regulations, and initiate effective supervisory action when 

elements of an institution’s compliance management system are deficient and/or violations are found. To 

promote the most effective and efficient use of resources, the consumer compliance examination 

program focuses on the activities and products that pose the greatest potential risk of consumer harm or 

otherwise require increased supervisory attention.
35

In addition to its examination program, the FDIC investigates consumer complaints about FDIC-supervised 

IDIs regarding consumer protection and fair lending issues. Through its investigation of, and response to,

those complaints and inquiries, the FDIC attempts to help consumers better understand their rights under 

federal consumer protection and fair lending laws. The FDIC uses surveys to monitor consumers’ 

satisfaction with its responses to complaints and inquiries.

Cybersecurity

Cybersecurity remains an ongoing concern for the financial services sector because of the reliance on IT 

not only in bank operations, but also as an interface with customers. The frequency and sophistication of 

cyberattacks continues to increase, and the financial services sector is a prime target. In response, 

financial institutions and their service providers are continually challenged to assess the quickly changing 

risks and to allocate adequate resources to mitigate those risks to an acceptable level.

The FDIC monitors cybersecurity issues on a regular basis, through on-site examinations of insured 

institutions, participation in the Financial and Banking Information Infrastructure Committee (FBIIC), 

threat monitoring (through its membership in the Financial Services Information Sharing and Analysis 

Center), and examination of services delivered to IDIs by certain service providers.

The FDIC, along with the other members of the Federal Financial Institutions Examination Council 

(FFIEC),4 maintain the FFIEC IT Examination Handbook, which provides examination guidelines and 

procedures to equip examiners to evaluate risk management practices related to information technology 

and operations. The FDIC, in concert with other agencies, also assesses cybersecurity risk management

practices horizontally at LCFIs and service providers to help institutions mitigate the level of risk in the

financial system.

 4 See Appendix D for more information about the FFIEC, its members, and its functions.
36

Technology and Innovation

The FDIC continues to leverage technology to improve the efficiency and effectiveness of its supervision 

efforts and reduce the compliance burden for institutions, especially community banks, without 

sacrificing the quality of the FDIC’s supervision program. For example, the FDIC continues to seek ways to 

improve the receipt and review of imaged loan files and to tailor examination request lists. During 2023, 

the FDIC began exploring the potential for viewing imaged loan files at service providers rather than 

requiring institutions to send imaged loan files to the FDIC. This effort will continue in 2024. This project, 

if successful, will make it easier for institutions with imaged loan files to fulfill pre-examination request 

lists.

The FDIC is additionally implementing comprehensive plans to modernize its existing technology for 

managing the supervision program through its Risk Management Supervision Business Process 

Modernization (RMS BPM) initiative, which will transform the current disjointed application-centric 

environment into one that is process-centric and significantly more user-friendly. Through this program, 

the FDIC will increase supervision efficiency and effectiveness for internal and external stakeholders by 

streamlining and automating processes; providing greater ability to leverage robust analytics for 

informed decision-making; and reducing the time users need to move between systems and manually 

enter information. In 2024, the FDIC will also complete the deployment of its new FOCUS application 

(Framework for Oversight of Compliance and CRA Activities User Suite) that supports its consumer 

compliance examination program.

Emerging Issues

Each of the FDIC’s supervisory programs is alert to potential emerging issues and the risks they could pose 

to IDIs. In light of the failures of three large regional banks in early 2023, the FDIC is adapting and 

updating its monitoring programs to enhance identification of emerging issues and to address regulatory 

concerns regarding areas of heightened risk, including interest rate risk, funding risk, and rapid growth. 

As part of this effort, the FDIC is exploring automated methods for collecting key monitoring data directly 

from institutions’ core service providers.
37

There are several additional areas of priority focus in 2024: 

• Implementing responses to the lessons learned from the failures of three large 

regional banks in early 2023;

• Reviewing the capital, liquidity, resolution plan, and potentially other rules to address 

the lessons learned from recent events;

• Beginning development of training and interagency examination procedures for 

examiners and bankers on the new CRA rule;

• Revisiting the regulatory framework and process used by the bank regulatory 

agencies to review proposed bank mergers to consider their effectiveness in meeting 

statutory requirements, such as competitive factors, the convenience and needs of 

the community, and financial stability; 

• Continuing to assess the potential safety and soundness, consumer protection, 

resolution, and financial stability risks posed by fintech activities and by digital asset 

or crypto-related activities at IDIs, and providing appropriate supervisory feedback; 

• Finalizing and implementing the Basel III capital rules to strengthen the regulatory 

capital framework for large banking organizations in coordination with other federal 

regulators; 

• Implementing changes to the FDIC signage, advertising, and misrepresentation rules 

to keep pace with changes in the financial services marketplace and to clarify for 

consumers when they are engaged in transactions with an FDIC-insured institution 

and with an FDIC-insured product; and

• Continuing to engage with the interagency initiative to address concerns about 

discrimination in home mortgage appraisals, including implementing the 

recommendations described in the Property Appraisal and Valuation and Equity 

(PAVE) Action Plan.5

 

5 The PAVE Action Plan was developed by the Interagency Task Force on Property Appraisal and Valuation Equity, 

which includes 13 federal agencies and offices, including the FDIC. The Action Plan is available at 

https://pave.hud.gov/sites/pave.hud.gov/files/documents/PAVEActionPlan.pdf. 
38

The following table depicts the strategic goal, strategic objective, and annual performance goals 

for the Risk Management component of the Supervision Program.

Strategic Goal Strategic Objective Annual Performance Goals

FDIC-insured 

institutions 

are safe and 

sound.

The FDIC exercises its 

statutory authority, 

in cooperation with 

other primary federal 

regulators and state 

agencies, to promote 

safe and sound 

practices at FDICinsured depository 

institutions, 

including appropriate 

risk management.

Conduct on-site risk 

management examinations to 

assess the overall financial 

condition, management 

practices and policies, and 

compliance with applicable laws 

and regulations of FDICsupervised depository 

institutions. When problems are 

identified, promptly implement 

appropriate corrective programs 

and follow up to determine 

whether identified problems are 

corrected and take other actions 

as appropriate. (2.1-1)

Assist in protecting the 

infrastructure of the U.S. banking 

system against terrorist 

financing, money laundering, 

and other financial crimes. (2.1-

2)

Ensure that risk-based capital 

standards sufficiently capture 

risk, remain robust, and promote 

banks’ resilience under stress. 

(2.1-3)

Implement strategies to promote 

enhanced cybersecurity and 

business continuity within the 

banking industry. (2.1-4)

Update rules, regulations, and 

other guidance to promote the 

safety and soundness of the 

financial system. (2.1-5)

Increase engagement and 

collaboration to preserve and 
39

promote FDIC-insured minority 

depository institutions (MDIs) 

and mission-driven institutions. 

(2.1-6)
40

The following table depicts the strategic goal, strategic objectives, and annual performance goals for the 

Consumer Compliance and Consumer Affairs components of the Supervision Program.

Strategic Goal Strategic Objectives Annual Performance Goals

FDIC-supervised 

institutions are 

compliant with federal 

consumer protection 

laws, including fair 

lending laws, and the 

Community 

Reinvestment Act (CRA).

The FDIC supervises 

institutions for 

compliance with 

applicable federal 

consumer protection 

laws, including fair 

lending laws; the law 

against unfair and

deceptive practices; 

and the CRA.

Conduct on-site CRA and 

consumer compliance 

examinations to assess 

compliance with applicable 

laws and regulations by FDICsupervised institutions. When 

violations are identified, 

promptly implement 

appropriate corrective 

programs/actions and follow 

up until identified problems 

are fully corrected. (3.1-1)

The FDIC provides clear 

and accessible 

information to 

consumers about their 

rights under federal 

consumer protection 

and fair lending laws 

and regulations, 

including applicable 

disclosures.

Effectively investigate and 

respond to written consumer 

complaints and inquiries about 

FDIC-supervised financial 

institutions. (3.2-1)

The FDIC encourages 

IDIs to offer affordable 

checking and savings 

accounts and loan 

products that meet the 

needs of consumers.

Promote economic inclusion 

and access to responsible 

financial services through 

supervisory, research, policy, 

and consumer/community 

affairs initiatives. (3.3-1)
41

The following table depicts the strategic goal, strategic objectives, and annual performance goals for the 

Resolution Planning component of the Supervision Program.

Strategic Goal Strategic Objective Annual Performance Goal

Large, complex financial 

institutions are resolvable 

in an orderly manner. 

Large, complex 

financial 

institutions are 

resolvable under 

the bankruptcy 

code or, for 

covered IDIs, the 

FDI Act, as 

applicable.

Identify and address risks in 

LCFIs, including those 

designated as systemically 

important. (4.1-1)

In the event of the 

failure of a large, 

complex financial 

institution, the 

FDIC carries out the 

resolution in an 

orderly manner in 

accordance with 

statutory 

mandates.

Continue to build the FDIC’s 

operational readiness to 

administer the resolution of 

LCFIs, including those 

designated as systemically 

important. (4.2-1)
42

STRATEGIC GOAL 2:

FDIC-insured institutions are safe and sound.

STRATEGIC OBJECTIVE 2.1

The FDIC exercises its statutory authority, in cooperation with other primary federal regulators and state 

agencies, to promote safe and sound practices at FDIC-insured institutions, including appropriate risk 

management.

Annual Performance Goal 2.1-1

Conduct on-site risk management examinations to assess the overall financial condition, management 

practices and policies, and compliance with applicable laws and regulations of FDIC-supervised 

depository institutions. When problems are identified, promptly implement appropriate corrective 

programs and follow up to determine whether identified problems are corrected and take other actions 

as appropriate.

Indicators and Targets

1. Percentage of required examinations conducted in accordance with statutory 

requirements and FDIC policy

• Conduct all required risk management examinations within the timeframes 

prescribed by statute and FDIC policy.

2. Follow-up actions on identified problems

• For at least 90 percent of IDIs that are assigned a composite CAMELS rating

of 2 and for which the examination report identifies Matters Requiring Board 

Attention (MRBAs), review progress reports and follow up with the 

institution within six months of the issuance of the examination report to 

determine whether all MRBAs are being addressed.
43

• Continue to implement appropriate actions in response to the matters 

identified for further study in the comprehensive reviews of the failures of 

Signature Bank and First Republic Bank. 

Means and Strategies

Operational Processes (initiatives and strategies): Risk management examinations assess the overall 

financial condition, management practices and policies, and compliance with applicable laws and 

regulations of FDIC-supervised institutions. The FDIC performs safety and soundness, AML/CFT, and IT

reviews at each risk management examination of an FDIC-supervised IDI. As applicable, the FDIC also 

conducts reviews of trust, registered transfer agent, municipal securities dealer, and government 

security dealer activities at these examinations.

In 2024, the FDIC projects that it will conduct more than 1,200 risk management examinations required 

under statute, FDIC policy, or agreements with state supervisors. The number of risk management 

examinations to be conducted during 2024 will fluctuate as the number of FDIC-supervised IDIs changes 

as a result of mergers, closings, newly approved charters, charter conversions, and other actions. In 

addition, increases in asset size or complexity, or changes to an institution’s condition or capital levels 

may accelerate examination cycles, increase the number of required examinations, or require a shift to a 

continuous exam process.

The examination report communicates examination findings to the institution’s management and board 

of directors. The report may identify financial weaknesses or risk management practices that, if left 

uncorrected, could result in deterioration of the institution’s financial condition. In those instances, the 

FDIC may ask the institution to report on the corrective measures taken to address the findings. If the 

findings are of significant concern, the FDIC may enter into an informal or formal enforcement action to 

address the findings. The FDIC evaluates an institution’s progress in addressing the provisions of the 

enforcement action by analyzing the institution’s regular progress reports, conducting on-site 

visitation(s), or by conducting a regular examination.
44

Human Resources (staffing and training): In 2024, the FDIC has 1,778 authorized positions in its workforce 

to conduct risk management examinations. Field examiners conduct on-site examinations and visits. 

These positions include a variety of examiners with specialized skills, such as large bank specialists, loan 

review analysts, and IT examiners and specialists. The FDIC maintains a robust examiner training 

program, including programs for developing specialized skills.

Case managers and other regional office officials finalize reports of examination and monitor 

compliance with enforcement programs. The FDIC also provides ongoing training for these individuals.

Information Technology: The FDIC’s Virtual Supervisory Information on the Net (ViSION) system is used 

to track the findings of risk management examinations and outcomes of applications. ViSION is also

used to monitor all enforcement activity and other significant events at troubled institutions and to track

on-site visits and follow-up examinations of institutions rated 3, 4, or 5.

As previously described, the FDIC is developing comprehensive plans to modernize its technology for 

managing the supervision program through its RMS BPM project. Through this project, the FDIC will 

replace software applications, including ViSION, with automated business processes residing on a cloudbased platform that ultimately will host end-to-end supervision processes. 

Verification and Validation

The number and timing of examinations are tracked through ViSION and reported through established 

management reporting processes. MRBAs are also tracked through ViSION. 

2023 Performance Results

The FDIC substantially met the performance targets for this annual performance goal in 2023. This 

annual performance goal and its associated performance indicators and targets are substantively

unchanged for 2024.
45

Annual Performance Goal 2.1-2

Assist in protecting the infrastructure of the U.S. banking system against terrorist financing, money 

laundering, and other financial crimes.

Indicator and Target

1. Percentage of required examinations conducted in accordance with statutory

requirements and FDIC policy

• Conduct all AML/CFT examinations within the timeframes prescribed by statute 

and FDIC policy.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC conducts AML/CFT examinations and Office of 

Foreign Assets Control (OFAC) reviews to assess the AML/CFT compliance programs and review OFAC 

compliance of FDIC-supervised institutions. These examinations and reviews cover sound risk 

management; compliance with the AML/CFT program requirements, recordkeeping, and reporting

requirements; the ability of the institution to identify and report suspicious activities; and compliance 

with trade and economic sanctions. AML/CFT examinations and OFAC reviews are performed as a part of 

all risk management examinations of FDIC-supervised institutions. The FDIC also completes AML/CFT

examinations and OFAC reviews for states that do not conduct these examinations. The FDIC follows a

risk-based approach to AML/CFT examinations and OFAC reviews, which allows examiners to direct

resources to those areas with the greatest potential for money laundering, terrorist financing, and other 

illicit financial activity risk.

Human Resources (staffing and training): More than 300 FDIC examiners are designated as AML/CFT

subject matter experts. Staffing and training needs are reviewed regularly to ensure the staff resources 

supporting the AML/CFT examination program are adequate and that employees possess the skills and 

knowledge to effectively and successfully assess compliance with AML/CFT requirements and detect any 

emerging risks.
46

Information Technology: ViSION is used to track the number and timing of required AML/CFT 

examinations. Examiners also use the Examination Tool Suite (ETS) to update AML/CFT violation codes 

automatically, thereby increasing the efficiency of those examinations. As previously described, the 

FDIC is developing comprehensive plans to modernize its technology for managing the supervision 

program through its RMS BPM project.

Verification and Validation

The number and timing of AML/CFT examinations are tracked in ViSION and reported through 

established management reporting processes.

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and its associated performance indicator and target are substantively unchanged for 

2024.

Annual Performance Goal 2.1-3

Ensure that risk-based capital standards sufficiently capture risk, remain robust, and promote banks’ 

resilience under stress.

Indicator and Target

1. U.S. implementation of internationally agreed capital standards and other capital 

standards for large institutions

• Issue a final rule to implement the final Basel III standards to strengthen capital 

requirements applicable to large banks into the U.S. regulatory capital framework. 
47

Means and Strategies

Operational Processes (initiatives and strategies): The Basel Committee on Banking Supervision reached 

a final agreement in 2017 on modifications to the Basel III international regulatory framework for the 

largest and most complex institutions. This final agreement would strengthen the regulatory framework 

for large banking organizations, including strengthening the capital requirements related to market risk, 

operational risk, and the risks associated with financial derivatives. In September 2022, the federal 

banking agencies publicly reemphasized their continued commitment to implementation of this final 

agreement. The proposed Basel III standards would address concerns regarding excessive variability in 

the measurement of risk-weighted assets (RWAs) across large internationally active banking institutions. 

They would enhance the market risk framework by introducing: 

• A clearer boundary between the trading book and the banking book;

• An internal models approach that relies upon the use of expected shortfall models;

• Separate capital requirements for risk factors that cannot be modeled; and 

• A risk-sensitive standardized approach that is designed and calibrated to be a credible fallback 

to the internal models approach.

The FDIC, OCC, and FRB plan to issue a final rule in 2024 to address these issues. 

Human Resources (staffing and training): In 2023, the FDIC continued to increase the number of staff with 

capital markets expertise by adding staff resources and providing internal and external training on 

liquidity, funding, capital, trading activities, financial modeling, and other capital market areas. The 

FDIC is also developing a formal on-the-job training (OJT) program to develop higher-level proficiencies 

in the capital markets specialty area.

Information Technology: The FDIC will use existing technology to accomplish this annual performance 

goal.
48

Verification and Validation

Progress in meeting this annual performance goal will be tracked through periodic meetings and 

established management reporting processes. The update of Basel III standards will be verified through 

the publication of a final rule in the Federal Register.

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and indicator are unchanged for 2024, but the associated performance target has 

been updated.

Annual Performance Goal 2.1-4

Implement strategies to promote enhanced cybersecurity and business continuity within the banking 

industry.

Indicator and Targets

1. Enhancement of cybersecurity awareness and preparedness of the banking industry

• Continue to conduct horizontal reviews that focus on the IT risks in large, complex 

institutions and service providers.

• Continue to conduct service provider examinations using the Cybersecurity 

Examination Program.

• Conduct IT examinations as part of every FDIC safety and soundness examination 

of FDIC-insured institutions.

• Amplify cybersecurity threat information as needed.

• Strengthen administration of the IT examination program.
49

Means and Strategies

Operational Processes (initiatives and strategies): The importance of cybersecurity and business 

continuity management to ensure the soundness and stability of the nation’s financial services sector 

cannot be overstated. The FDIC prioritizes this issue and adjusts its financial institution supervision and

bank service provider examinations to address cybersecurity risk in light of current and emerging 

threats. The majority of bank service provider examinations are conducted and scheduled on an 

interagency basis with the OCC and FRB. They are supplemented by annual horizontal reviews that 

focus on key areas of risk. Following an evaluation by the FDIC and the other agencies of the cyber 

resilience of the financial industry’s most critical service providers in 2022, the agencies conducted a 

horizontal assessment in 2023 of third-party risk and software supply chain security. In 2024, the 

agencies will review vulnerability management. In 2024, the FDIC will also focus on strengthening IT 

examination administration and formal assessment of the Regional Service Provider examination 

program to establish program-level goals, metrics, and indicators and determine whether additional 

resources and controls are needed to improve the effectiveness of the program.

In addition, the FDIC continues to participate with the FRB and OCC in the interagency Coordinated 

Cybersecurity Review Program, which allows the agencies to jointly conduct horizontal reviews of the 

eight largest financial institutions, focusing on the effectiveness of enterprise-wide cybersecurity 

governance and risk management functions. This program improves the efficiency of cybersecurity 

supervision of the largest financial institutions and allows the regulatory agencies to jointly focus on 

areas of highest risk. To support, but not replace, an institution’s threat information awareness 

program, the FDIC amplifies communications from law enforcement, security, and intelligence agencies 

when the threats or vulnerabilities identified could affect a large number of financial institutions, and 

the threats or vulnerabilities could result in severe disruptions to banking services or unauthorized 

access to non-public information.

Human Resources (staffing and training): All commissioned risk management examiners have basic IT

examination skills attained through the FDIC’s training programs.
50

The FDIC also has 94 dedicated IT examiners; 143 risk management examiners designated as either 

intermediate (122) or advanced (21) IT subject matter experts based on the completion of the FDIC’s IT 

OJT Subject Matter Expert program; and 68 specialized IT Examination Analysts, who support the IT

examination process with advanced technical skills. IT policy and examination personnel at 

headquarters also support the IT examination function.

Information Technology: ViSION is used to schedule and track the completion of risk management 

examinations, and to track any related enforcement actions or significant events at institutions due to 

noncompliance with IT-related banking laws and regulations.

As previously described, the FDIC is developing comprehensive plans to modernize its technology for 

managing the supervision program through its RMS BPM project. 

Verification and Validation

All IT examination activity (including service provider examinations) is tracked through FDIC systems. 

The number and timing of IT examinations are tracked through ViSION and reported through established 

management processes. Enforcement actions and the timing of required on-site visits are also tracked 

through ViSION. 

2023 Performance Results

The FDIC met the performance targets for this annual performance goal in 2023. This annual 

performance goal and its associated performance indicator are unchanged for 2024.

 

Annual Performance Goal 2.1-5

Update rules, regulations, and other guidance to promote the safety and soundness of the 

financial system.
51

Indicators and Targets

1. Modernization of FDIC regulations and Statements of Policy to reflect regulatory 

requirements and processes

• Review and, as appropriate, amend the FDIC’s regulations, Statements of Policy, 

and internal procedures related to financial institution mergers.

2. Revision and clarification of FDIC rules, regulations, policies, procedures, and guidance

• Continue to assess the potential safety and soundness, consumer protection, 

AML/CFT, and financial stability risks of crypto-asset related activities, and provide 

supervisory feedback or take other actions, as appropriate, regarding crypto assetrelated activities. 

• Based on lessons learned from the bank failures in early 2023, and in coordination 

with the OCC and FRB, recommend changes to the prudential regulation of capital, 

liquidity, and interest rate risk (including the capital treatment of unrealized losses).

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC has worked to strengthen the 

banking system by modernizing its approach to supervision and regulation. These efforts seek 

to enhance efficiency and transparency while maintaining the safety and soundness of the 

system. To have a strong financial system and strong economic growth, banks must be able to 

meet the needs of consumers and businesses. This requires, in turn, that regulators modernize 

rules as the industry evolves. Rules are also revised and updated to reflect the emergence of 

new areas of concern during the supervision process, such as those related to the failure of 

three large regional banks in early 2023. In 2024, the FDIC plans to complete an interagency 

review of the bank merger process and issue a proposed Statement of Policy on Bank Merger 

Transactions.
52

The FDIC has also prioritized understanding the effects of climate change on the safety and soundness of 

financial institutions and the stability of the financial system.6

 Climate-related financial risks include

both the physical risks and transition risks associated with climate change. Even though physical risks 

and transition risks pose separate and distinct financial risks to the financial system, they may operate in 

a mutually reinforcing manner in that transition risks can increase contemporaneously with any material 

increase in physical risks. Climate-related financial risks also raise consumer protection risks, as both 

the effects of climate change and the actions that financial institutions may take to manage climaterelated financial risks could potentially have a disproportionate impact on low-to-moderate income 

(LMI) and other underserved consumers and communities.

On October 24, 2023, the FDIC, FRB, and OCC jointly issued the final Principles for Climate-Related 

Financial Risk Management for Large Financial Institutions that provides a high-level framework for the 

safe and sound management of exposures to climate-related financial risks, consistent with the existing 

risk management framework described in existing FDIC rules and guidance. The principles are intended 

for large financial institutions with over $100 billion in total consolidated assets; however, the FDIC views 

climate-related financial risks as potentially affecting all financial institutions, regardless of size. 

Climate-related financial risks can affect financial institutions through a range of traditional risk types, 

including credit, market, and liquidity risks. The FDIC will continue to engage with banks of all sizes to 

better understand how climate-related financial risks may impact their businesses, and how they may 

better manage those risks. 

Another area of focus is the rapid introduction of a variety of crypto-asset or digital-asset products into 

the financial system. The risks associated with these activities are novel and complex, and may involve 

safety and soundness, consumer protection, AML, CFT, and potentially financial stability issues. The 

FDIC created an interdivisional working group to assess the enumerated risks and provide advice to staff 

developing interagency guidance. The FDIC also asked all supervised institutions that are already 

engaging or are considering engaging in crypto-related activities to provide information that would 

allow the FDIC to engage with them regarding related risks.

 

6 For additional background, see generally “Report on Climate-Related Financial Risk” Financial Stability Oversight 

Council (October 21, 2021) (FSOC Climate Report), https://home.treasury.gov/system/files/261/FSOC-ClimateReport.pdf. Further, see “The Implications of Climate Change for Financial Stability,” Financial Stability Board, 

(November 23, 2020), https://www.fsb.org/2020/11/the-implications-of-climate-change-for-financial-stability/. 
53

In addition, the FDIC, FRB, and OCC issued guidance in 2023 to all insured institutions reminding them 

that banking activities related to crypto-related assets must be performed in a safe and sound manner 

and comply with applicable laws and regulations, and highlighting key liquidity risks associated with

crypto-related assets.

More broadly, as it relates to emerging technology, the FDIC continues to dedicate significant resources 

to identifying and understanding emerging technologies and ensuring the FDIC is prepared to address 

the changing landscape in financial services. In 2023, the FDIC created a new Emerging Technology 

Section to provide examination support and lead policy development related to emerging technologies. 

In addition, the FDIC Tech Lab under the Chief Information Officer (CIO) provides support in evaluating 

the risks associated with new technologies. 

The FDIC, FRB, and OCC issued updated guidance to banking organizations on the management of risks 

associated with third-party relationships, including relationships with financial technology-focused 

entities. That guidance offers the agencies’ views on sound risk management principles for banking 

organizations when developing and implementing risk management practices for all stages in the life 

cycle of third-party relationships.

In October 2023, the FDIC published a Notice of Proposed Rulemaking (NPR) that would add Appendix C 

to the FDIC’s regulation for safety and soundness standards 12 C.F.R. § 364 et seq. (Part 364). Appendix C 

is intended to promote strong corporate governance and risk management at FDIC-supervised 

institutions that have total consolidated assets of $10 billion or more. It includes corporate governance 

and risk management guidelines that describe both the overall obligation of boards of directors to 

ensure good corporate governance and the general obligations of individual directors.

Human Resources (staffing and training): The FDIC maintains dedicated staff who are experts in 

the development of regulation, policy, and guidance within its Division of Risk Management 

Supervision (RMS) and Legal Division. There are also staff who have been developing subject 

matter expertise in a variety of specialized areas, including climate and digital assets. These 

experts will work together to carry out the policy initiatives listed above.
54

Information Technology: Information regarding changes to FDIC rules, regulations, and 

guidance will be communicated through the FDIC’s public website (https://www.fdic.gov). 

Verification and Validation

Progress in meeting this goal will be reported through established management reporting 

processes. 

2023 Performance Results

The FDIC met all of the performance targets for this annual performance goal in 2023 except the 

target to amend the FDIC’s regulations, Statements of Policy, and internal procedures related to 

financial institution mergers. This annual performance goal and indicators are unchanged; two 

performance targets have been carried over and the remainder have been updated for 2024.

Annual Performance Goal 2.1-6 

Increase engagement and collaboration to preserve and promote FDIC-insured minority 

depository institutions (MDIs) and mission-driven institutions.

Indicators and Targets

1. Enhance outreach and collaboration with FDIC-insured MDIs

• Convene meetings of the MDI Subcommittee of the Advisory Committee on 

Community Banking (CBAC) to gain insight into industry needs, seek input on 

program operations, and share best practices. 

• Facilitate partnership opportunities between larger banks and MDIs by collaborating 

in outreach and training regarding the benefits of CRA modernization. Collect and 

publish examples of successful partnerships.

2. Preserve and encourage minority ownership of insured financial institutions

• Promote the creation of new MDIs. 
55

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC supports five statutory goals that 

were established in the 1989 Financial Institutions Reform, Recovery, and Enforcement Act 

(FIRREA):

• To preserve the number of MDIs; 

• To preserve the minority character in cases involving the merger or acquisition of an 

MDI; 

• To provide technical assistance to help prevent insolvency of MDIs; 

• To promote and encourage creation of new MDIs; and 

• To provide training, technical assistance, and educational programs for MDIs. 

FDIC research shows that FDIC-insured MDIs commit a larger portion of their portfolios to

minority and LMI communities than comparable non-MDIs. MDIs are often the financial 

lifeblood of their communities, enabling individuals and small businesses to securely build 

savings and obtain credit in challenging economic environments.

Many mission-driven banks are small, and building capacity and scale are critical to growing 

their operations and expanding services to their communities. Access to the capital markets is a 

common challenge for many of these institutions. The FDIC regularly works to create 

opportunities for FDIC-insured MDIs to build partnerships with other banks or private 

companies for financial support, lending, and other services, including technical assistance. 

The FDIC also supports MDIs by providing these institutions with technical assistance, sponsoring 

banker roundtables, providing education and training, and engaging in other outreach initiatives.

In 2023, the FDIC continued to engage the MDI Subcommittee for feedback and to showcase MDI 

best practices, highlight the role these institutions play in their communities, and promote the 

visibility and benefits of mission-driven banks. The FDIC will continue to highlight successful 

partnerships in 2024, and develop outreach and training regarding CRA modernization that 

offers specific benefits to institutions that partner with MDIs and CDFIs.
56

The FDIC will build upon its efforts to promote new MDIs through the publication of an 

interactive mapping tool showing census tracts with large minority populations overlaid with 

MDI, community bank, and large bank branch locations. The tool can be used to identify future 

business opportunities for serving minority populations.

Human Resources (staffing and training): The Office of Minority and Community Development 

Banking includes the Director and a team based in Washington, DC. The Director reports to the 

Directors of the RMS and the Division of Depositor and Consumer Protection (DCP) to leverage 

resources and expertise in the two divisions. The Office accomplishes much of its work by 

leveraging field and regional resources through MDI Coordinators in each of the FDIC’s six 

regional offices and expertise across the agency. 

Information Technology: Existing technology will be used to accomplish this goal.

Verification and Validation

Progress in completing the initiatives planned for this annual performance goal will be 

monitored through established management reporting processes.

2023 Performance Results

The FDIC successfully met the performance targets for this annual performance goal in 2023. 

This annual performance goal and its associated performance indicators are unchanged, but the 

performance targets have been updated for 2024.

STRATEGIC GOAL 3:

FDIC-supervised institutions are compliant with federal consumer protection laws, including fair lending 

laws, and the Community Reinvestment Act (CRA).
57

STRATEGIC OBJECTIVE 3.1

The FDIC supervises institutions for compliance with applicable federal consumer protection laws, 

including fair lending laws; the law against unfair and deceptive practices; and the CRA.

Annual Performance Goal 3.1-1

Conduct on-site CRA and consumer compliance examinations to assess compliance with applicable laws 

and regulations by FDIC-supervised institutions. When violations are identified, promptly implement 

appropriate corrective programs/actions and follow up until the violations are fully corrected.

Indicators and Targets

1. Percentage of consumer compliance examinations conducted in accordance with the 

timeframes prescribed by FDIC policy

• Conduct all required examinations within the timeframes established.

2. Implementation of corrective programs

• Conduct visits and/or follow-up examinations in accordance with established FDIC 

processes and timeframes to determine whether institutions have implemented the

requirements of any corrective program and have fully addressed identified 

violations.

3. Implementation of new CRA Rule

• Develop examiner and banker awareness training on the interagency final rule to 

modernize and strengthen CRA regulations. 

• Begin development of interagency examination procedures on the final CRA rule. 
58

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC conducts CRA and consumer compliance 

examinations of FDIC-supervised institutions to determine compliance with consumer protection and 

fair lending laws and performance under the CRA.

The frequency of consumer compliance examinations is specified by FDIC policy. For CRA examinations, 

the FDIC’s examination frequency policy conforms to applicable provisions of the Gramm-Leach-Bliley 

Act (GLBA), which establishes the CRA examination cycle for most small institutions. In 2024, the FDIC 

estimates that it will conduct 900 consumer compliance and/or CRA examinations. The FDIC’s consumer 

compliance examination approach emphasizes a risk-focused scoping process to look at an institution’s 

compliance risk management practices and the potential risk of consumer harm.

Compliance management system deficiencies and violations of laws and regulations are identified 

primarily through the examination process. While discussions with bank management are usually 

sufficient to correct these deficiencies and violations, the FDIC has broad enforcement powers to correct 

unsafe or unsound practices, conditions, or violations of consumer protection and fair lending laws or 

regulations.

The banking agencies approved a new CRA rule in October 2023, with most provisions effective at the 

beginning of 2026. The agencies will develop awareness training for examiners and bankers and will 

begin developing interagency examination procedures on the new CRA rule in 2024.

Human Resources (staffing and training): The FDIC has 479 authorized compliance examiner positions in 

its field examination workforce in 2024. Staffing and training needs are reviewed regularly to ensure 

staff resources supporting the consumer compliance supervision program are adequate to conduct a 

high-quality examination program and to ensure that employees possess the skills and knowledge to 

effectively implement this program.
59

Information Technology: FOCUS is used to conduct and provide management information on consumer 

compliance and CRA examinations, including pre-examination planning, resource planning and 

scheduling, and the storage of examination workpapers.

Verification and Validation

The FDIC will analyze examination-related data collected in FOCUS to determine whether the 

performance targets for this goal are achieved during the reporting period. Results will be reported 

through established management reporting processes. 

2023 Performance Results

The FDIC substantially met the performance targets for the annual performance goal in 2023. This 

annual performance goal, two indicators, and their associated performance targets are unchanged for 

2024. One performance indicator and its associated performance targets have been updated.

STRATEGIC OBJECTIVE 3.2

The FDIC provides clear and accessible information to consumers about their rights under federal 

consumer protection and fair lending laws and regulations, including applicable disclosures.

Annual Performance Goal 3.2-1

Effectively investigate and respond to written consumer complaints and inquiries about FDIC-supervised 

financial institutions.
60

Indicators and Targets 

1. Timely responses to written consumer complaints andinquiries

• Respond to 95 percent of written consumer complaints and inquiries within 

timeframes established by policy, with all complaints and inquiries receiving atleast 

an initial acknowledgement within twoweeks.

2. Public availability of information on consumer complaints

• Publish on the FDIC’s public website (https://www.fdic.gov) and regularly update

metrics on requests from the public for FDIC assistance.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC has a comprehensive program to disseminate 

information to IDIs and the public on consumer rights under consumer protection and fair lending laws 

and regulations. It also operates a centralized National Center for Consumer and Depositor Assistance 

(NCDA) that coordinates the investigation of, and response to, consumer complaints and inquiries. For 

correspondence related to FDIC-supervised institutions, FDIC staff contacts the institution and reviews 

its actions for compliance with applicable federal consumer protection regulations before providing a 

response. Correspondence regarding institutions under the jurisdiction of other primary federal 

regulators is referred to those agencies. Target response times vary by the type of inquiry or complaint.

Human Resources (staffing and training): The NCDA is based in Kansas City, MO. NCDA staff and 

management work in partnership with supervisory staff in each region on consumer complaints and 

inquiries involving new or unusual issues or sensitive matters. The NCDA staff also includes deposit 

insurance specialists to answer complex consumer concerns about deposit coverage.

Information Technology: The FDIC relies on the Enterprise Public Inquiry and Complaint System (EPIC) to 

maintain records and process public correspondence submitted through an online portal. 
61

Verification and Validation

The FDIC closely monitors the timeliness of its acknowledgment letters and responses through EPIC. In 

addition, surveys are sent to consumers who have filed consumer protection and fair lending complaints 

about an FDIC-supervised institution to assess their satisfaction with the FDIC’s investigations and 

responses. Established survey research methods are used to ensure the validity and reliability of the 

survey instrument and results. Performance results are monitored through established management 

reporting processes.

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and its associated performance indicator and targets are unchanged for 2024.

STRATEGIC OBJECTIVE 3.3

The FDIC encourages IDIs to offer affordable checking and savings accounts and loan products that meet 

the needs of consumers.

Annual Performance Goal 3.3-1

Promote economic inclusion and access to responsible financial services through supervisory, research, 

policy, and consumer/community affairs initiatives.

Indicator and Targets

1. Completion of planned initiatives

• Analyze and report results of the 2023 National Survey of Unbanked and 

Underbanked Households. 
62

• Analyze and report results of the FDIC Survey of Volunteer Income Tax 

Assistance (VITA) Providers.

• Complete identification and evaluation of outcome-based measures that could 

potentially demonstrate the effectiveness of economic inclusion strategies and 

initiatives.

Means and Strategies

Operational Processes (initiatives and strategies): In 2024, the FDIC will advance several research and 

consumer/community affairs initiatives to promote economic inclusion. 

Research

In June 2023, the FDIC conducted the FDIC 2023 National Survey of Unbanked and Underbanked 

Households, jointly with the U.S. Census Bureau. The survey measures household participation in the 

banking system and provides insights into opportunities to expand and support consumers’ access and 

use of products and services from insured depository institutions. In 2024, the FDIC will receive final 

data, analyze results, and publish a full report of findings. In addition, detailed data and tools to allow 

the public to generate custom tables and figures will be made available through the FDIC’s website.

The FDIC also conducted in 2023 a survey of volunteer income tax assistance (VITA) providers. The FDIC

Survey of VITA Providers was designed to explore the ways in which VITA providers are currently helping 

consumers establish banking relationships and to identify challenges that some providers may face in 

forming partnerships with financial institutions. The FDIC will publish a full report of findings in 2024.

Economic Inclusion Strategic Plan 

The FDIC updated its multi-year Economic Inclusion Strategic Plan in 2023. The plan describes programs 

and initiatives to be undertaken by the FDIC to promote access by all U.S. households to affordable and 

sustainable products and services from IDIs so that they may establish, sustain, and benefit from 

banking relationships that help them create and grow a strong financial foundation.
63

The FDIC will publish and begin implementation of this multi-year plan in early 2024. In 2024, the FDIC 

will also update the plan’s economic inclusion key performance indicators, establish a monitoring 

process and reporting tool to assess progress toward its goals, and provide training and resources to 

staff to facilitate consistent data tracking and collection.

How Money Smart Are You? 

The FDIC administers How Money Smart Are You? a self-paced, web-based financial education game that 

aims to empower consumers to better control their finances and protect and manage their money. 

Since launching the tool in 2021, the FDIC has issued nearly 230,000 certificates of completion, and has 

established more than 68,000 individual player accounts and more than 1,100 organization accounts. In 

2024, the FDIC will continue to promote How Money Smart Are You?, while conducting a formal 

evaluation to inform future updates and better understand its impact on knowledge and behavior.

In 2022, the FDIC completed development of a comprehensive update of its Money Smart for Young 

Adults (MSYA) curriculum, which was widely distributed in early 2023. The new MSYA seeks to help 

young adults make better financial choices early in life, contributing to a long-lasting positive impact on 

their financial lives. The FDIC will continue to promote the new MSYA in 2024, including in relation to 

safe and responsible youth account access initiatives and other youth-focused Money Smart products, 

such as the Guide to Organizing Reality Fairs. 

Advisory Committee on Economic Inclusion (ComE-IN) 

The ComE-IN will continue to support research, programs, and pilots that promote sound supervisory 

and public policies to improve the “appropriate engagement” of households with mainstream financial 

institutions. Appropriate engagement means that households are able to obtain financial products and 

services that are affordable, easy to understand, and not subject to unforeseen fees. The ComE-IN may 

make recommendations to the FDIC that require the participation and cooperation of multiple 

stakeholders, including other federal agencies; federal, state, and local policymakers; the financial 

services industry; nonprofit and philanthropic groups; and consumer groups.
64

During 2024, FDIC working groups will continue to facilitate partnerships and conduct outreach to 

expand affordable account access and build consumer awareness of mainstream banking services and 

opportunities for financial institutions to engage in community development. The FDIC may seek advice 

and recommendations on these initiatives from the ComE-IN. 

Human Resources (staffing and training): This annual performance goal will be carried out principally by 

existing staff in the DCP. ComE-IN activities are supported by FDIC staff in several divisions. 

 

Information Technology: Existing technology will be used to accomplish this goal. The ComE-IN’s public 

meetings are broadcast on the FDIC public website at https://www.fdic.gov/about/comein. 

 

Verification and Validation

 

Progress in achieving this annual performance goal will be monitored through established management 

reporting processes.

2023 Performance Results

 

The FDIC substantially met the performance targets for this annual performance goal in 2023. The 

annual performance goal and performance indicators are unchanged, but the performance targets have 

been updated for 2024. 
65

STRATEGIC GOAL 4:

Large, complex financial institutions are resolvable in an orderly manner.

STRATEGIC OBJECTIVE 4.1

Large, complex financial institutions are resolvable under the bankruptcy code or, for covered IDIs, the 

Federal Deposit Insurance (FDI) Act, as applicable.

Annual Performance Goal 4.1-1

Identify and address risks in LCFIs, including those designated as systemically important.

Indicators and Targets

1. Compliance with the statutory and regulatory requirements under Title I of the DoddFrank Act

• In collaboration with the FRB, complete review of the resolution plans submitted in 

July 2023 pursuant to Section 165(d) of the Dodd-Frank Act for conformance to 

statutory and other regulatory requirements, including testing certain capabilities 

the firms need to successfully implement their strategies. 

• In partnership with the FRB, complete a review of comments received in response to 

the NPR published in September 2023, and recommend to the FDIC Board a 

proposed final rule requiring LCFIs to issue long-term debt to enhance options for 

their resolution in the event of financial distress.

• In partnership with the FRB, recommend to the Board proposed final guidance on 

resolution plans submitted pursuant to Section 165(d) of the Dodd-Frank Act by 

BHCs that are classified as “Triennial Full Filers.”
66

2. Compliance with the statutory and regulatory requirements under Section 360.10 of the 

FDIC Rules and Regulations (IDI rule)

• Review resolution plans submitted pursuant to the IDI rule for conformance to 

regulatory requirements.

• Implement improvements to the FDIC’s review of IDI resolution plans based on the 

lessons learned from prior reviews and the three large regional bank failures in early 

2023.

• Recommend to the Board a proposed final rule to strengthen resolution planning 

requirements for IDIs.

3. Risk monitoring of LCFIs, including BHCs, and designated non-banking firms

• Conduct ongoing risk analysis and monitoring of LCFIs to better understand and 

assess their structure, business activities, risk profiles, and recovery and resolution 

plans.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC’s Division of Complex Institution Supervision 

and Resolution (CISR) is responsible for conducting ongoing risk monitoring reviews of all banking 

organizations with more than $100 billion in assets not directly supervised by the FDIC, as well as any 

non-bank financial companies designated as systemically important by the FSOC (i.e., designated nonbank SIFIs). The agency’s ability to analyze and respond to risks in these institutions is particularly 

important, as they comprise a significant share of banking industry assets and deposits. In 2024, the 

FDIC will participate in targeted examinations and horizontal reviews conducted by the OCC and FRB 

covering key risks within the FDIC portfolio; prepare written analyses of the condition of each insured 

bank and its parent company; and prepare risk-specific reports with both firm-specific and horizontal 

analysis and the overall market view on key risks facing LCFIs. The FDIC will also continue to develop its 

capabilities related to its risk-monitoring and resolution-planning responsibilities for LCFIs, whether 

under the FDI Act or the Dodd-Frank Act, and will undertake several initiatives to identify and address 

risks in LCFIs, including those designated as systemically important. 
67

The FDIC and FRB are jointly responsible for reviewing the resolution plans filed by BHCs and designated 

non-bank SIFIs to ensure that each provides a credible plan for reorganizing a firm or liquidating it 

through bankruptcy without triggering severe adverse consequences for the financial system or the U.S. 

economy. In 2024, the FDIC and FRB will implement changes, as needed, in the review process to ensure 

that it provides an effective and rigorous framework for meeting the agencies’ responsibilities under the 

Dodd-Frank Act. The FDIC and the FRB will also finalize guidance proposed in September 2023 on 

resolution plans submitted by BHCs that are classified as “Triennial Full Filers” (typically those with 

more than $250 billion in assets that are not GSIBs). The agencies issued an NPR in September 2023 

soliciting public comment on a proposed rule requiring large banking organizations and their IDIs to 

issue long-term debt to enhance options for the orderly resolution of the nation’s largest and most 

complex banks in the event of financial distress. In 2024, in collaboration with the FRB, agency staff will 

review those comments and recommend to the FDIC Board a final rule requiring LCFIs to issue long-term 

debt to enhance options for their resolution in the event of financial distress.

The FDIC will continue to prepare in 2024 for the potential future resolution of a large IDI. This will 

include review and analysis of the resolution plans submitted by IDIs in December 2023. In addition,

based on the lessons learned from the failure of three large regional banks in early 2023, the FDIC will 

identify and implement changes to ensure an effective and rigorous framework for IDI plan review and 

assessment and will develop proposed changes to the IDI rule to strengthen current resolution planning 

requirements.

The FDIC’s resolution planning in 2024 will continue to focus on systemically important central 

counterparties (CCPs). CCPs play a critical role in the financial system—their clearing services are central 

to U.S. financial markets—and accordingly, the FDIC is focused on resolution outcomes that avoid or 

mitigate serious adverse effects on U.S. financial stability and ensure that critical services provided by 

CCPs remain available.

Human Resources (staffing and training): The FDIC’s review of resolution plans submitted under Section 

165(d) of the Dodd-Frank Act is carried out by a multidisciplinary team of personnel from various 

divisions with expertise across all major operational and business line functions of the covered 

companies, both domestically and internationally.
68

The FDIC’s review of resolution plans submitted under the IDI Rule is carried out by multidisciplinary 

teams primarily consisting of commissioned examiners and resolution specialists. These teams are 

complemented by subject matter experts, as necessary. Training needs for each of these groups are 

reviewed regularly to ensure that they have the knowledge and expertise necessary to appropriately 

perform their assigned responsibilities. Ongoing risk monitoring of LCFIs is conducted by on-site

resident teams and off-site analysts.

Information Technology: The FDIC uses existing technology to track the submission and review of the 

resolution plans required under Section 165(d) of the Dodd-Frank Act and Section 360.10 of the FDIC 

Rules and Regulations.

Verification and Validation

Progress in achieving this annual performance goal will be monitored through established management 

reporting processes.

2023 Performance Results

The FDIC successfully met the performance targets for this annual performance goal in 2023. This

annual performance goal and its associated performance indicators are unchanged, but the 

performance targets have been updated for 2024.

STRATEGIC OBJECTIVE 4.2

In the event of the failure of a large, complex financial institution, the FDIC carries out the resolution in 

an orderly manner in accordance with statutory mandates.

Annual Performance Goal 4.2-1

Continue to build the FDIC’s operational readiness to administer the resolution of LCFIs, including those 

designated as systemically important.
69

Indicators and Targets

1. Refinement of resolution plans and strategies

• Continue to refine plans and strategic options to ensure the FDIC’s operational 

readiness to administer the resolution of LCFIs.

2. Continued cross-border coordination and cooperation in resolution planning

• Continue to deepen and strengthen working relationships with key foreign 

jurisdictions, both on a bilateral basis and through multilateral venues.

Means and Strategies

Operational Processes (initiatives and strategies): The largest BHCs are required to prepare resolution 

plans under Title I of the Dodd-Frank Act. These resolution plans must demonstrate that the firm could 

be resolved under bankruptcy without triggering serious adverse effects on financial stability in the 

United States. As a backstop, for circumstances in which an orderly bankruptcy process might not be 

possible, Title II of the Dodd-Frank Act provides the FDIC with the Orderly Liquidation Authority (OLA) to 

manage the failure of the firm. This authority may only be implemented after recommendations by the 

appropriate federal regulatory agencies and a determination by the Secretary of the Treasury in 

consultation with the President. In addition, as noted above, the FDIC is continuing to develop its 

planning and preparedness to enhance options for the orderly resolution under the FDI Act of IDIs that 

are LCFIs. 

Given the challenges presented in the resolution of an LCFI—especially as these companies are currently 

organized and operated—the FDIC initially focused its efforts on developing a resolution strategy called 

the single point of entry. This strategy would place the top-tier parent company of the firm into 

receivership, while establishing a temporary bridge financial company (BFC) to hold and manage its 

critical operating subsidiaries for a limited period. To operate the BFC, the FDIC would appoint a new 

board of directors and senior management that would be charged with managing the wind-down of the 

firm in a way that minimizes systemic disruption. Losses would be borne by creditors, including holders 

of long-term debt and equity, in accordance with the priorities established under the OLA.
70

The FDIC expects that the BFC and its subsidiaries would be well capitalized and in a position to borrow 

from customary private market sources to meet liquidity needs. However, if such funding is not 

immediately available, the law provides a dedicated, back-up source of liquidity—not capital—through 

the Orderly Liquidation Fund (OLF). The OLF would be used, if necessary, in the initial stage of resolution 

until private funding could be accessed.

Advance planning and cross-border coordination are essential to prepare for the orderly resolution of 

systemically important financial companies with significant international operations. Recognizing that 

such financial companies present complex cross-border legal and operational planning challenges, the 

FDIC works on an ongoing basis with foreign regulators to operationalize, maintain, and enhance 

frameworks for effective cross-border cooperation. The FDIC will continue to engage bilaterally and 

multilaterally in 2024 with authorities in strategically important foreign jurisdictions to further develop 

resolution strategies for GSIBs that are chartered or have a substantial presence in the U.S.

The FDIC, jointly with the FRB, or with the Commodity Futures Trading Commission (CFTC) or Securities 

and Exchange Commission (SEC), as applicable, also will convene meetings of Crisis Management 

Groups (CMGs) for U.S. GSIBs and CCPs and attend meetings of CMGs for non-U.S. GSIBs and CCPs with 

significant U.S. operations or other nexus. The FDIC will also participate in other activities intended to 

advance cross-border cooperation in furtherance of resolution planning by firms and authorities. The 

FDIC currently chairs the Financial Stability Board’s Resolution Steering Group (ReSG). The FDIC is also a 

member of ReSG and its constituent cross-border crisis management working groups for banks, financial 

market infrastructures, and insurers. 

Human Resources (staffing and training): This annual performance goal will be carried out by existing 

and newly on-boarded FDIC staff, with contractor support for certain functions. The training needs of 

staff are reviewed regularly to ensure that teams have the knowledge and expertise necessary to 

appropriately perform their assigned responsibilities.

Information Technology: Existing IT systems from the failed institution will be used in the resolution of a 

large, complex firm. The FDIC will continue to identify other IT needs relative to a failure of a large, 

complex financial institution during 2024.
71

Verification and Validation

The FDIC draws on its experience resolving IDIs and has devoted considerable time and resources to 

advance its planning for the rapid and orderly resolution of LCFIs. To evaluate the effectiveness of these 

planning efforts and to identify areas of further development, the FDIC holds operational exercises to 

validate the steps involved in carrying out a systemic resolution. In addition, the resolution strategies 

are presented and discussed in international venues, including CMG meetings and several other 

international platforms, for engagement among senior staff of supervisory and resolution authorities 

focused on resolution planning to continue to deepen and stengthen working relationships with key 

foreign jurisdictions.

2023 Performance Results

The FDIC successfully met the performance targets for this annual performance goal in 2023. This 

annual performance goal and its associated performance indicators and targets are substantively 

unchanged for 2024.
72

III. RECEIVERSHIP MANAGEMENT PROGRAM

Program Overview

Strategic Goal 5: Resolutions are orderly and receiverships are managed effectively.

Strategic Objective 5.1: The FDIC manages receiverships to maximize net return and terminates them in 

an orderly and timely manner.

Annual Performance Goal 5.1-1 (page 76) Value, manage, and market assets of failed IDIs and 

their subsidiaries in a timely manner to maximize the net return.

Annual Performance Goal 5.1-2 (page 78) Manage the receivership estate and its subsidiaries 

toward an orderly termination.

Strategic Objective 5.2: The FDIC manages receiverships to maximize net return and terminates them in 

an orderly and timely manner.

Annual Performance Goal 5.2-1 (page 80) Conduct investigations into all potential professional 

liability claim areas for all failed IDIs and decide as promptly as possible to close or pursue each 

claim, considering the size and complexity of the institution.
73

Receivership Management Program Overview

The FDIC promotes stability and public confidence and in the nation’s financial system through its 

receivership management program. When an IDI fails, the FDIC is appointed receiver. In its receivership 

capacity, the FDIC assumes responsibility for efficiently achieving maximum recoveries from the 

disposition of assets from the receivership. These recoveries are then distributed to the receivership’s 

creditors under the priorities set by law.

Prior to failure, the FDIC typically has the opportunity to analyze the assets and liablities of a failing IDI to 

determine its current market value. This information is used by the FDIC to market and sell the IDI in 

whole or in part to qualified bidders. The FDIC markets failed IDIs broadly, ensuring that all qualified 

bidders are given an opportunity to present bids. Bids are evaluated and compared to the estimated cost 

of liquidation to determine the least-costly resolution.

In the event an assuming institution cannot be found, the FDIC uses other types of resolution transactions 

including the following:

• Payout, where insured funds are paid directly to depositors; 

• Deposit Insurance National Bank (DINB), where a temporary national bank is established with 

limited life to assume the insured deposits of a failed IDI and allow depositors time to move their 

insured accounts to other institutions; or 

• Bridge Bank, where a temporary national bank is established and operated by the FDIC on an 

interim basis, assuming the assets and liabilities of a failed IDI until final resolution can be 

accomplished. 

The “Recordkeeping for Timely Deposit Insurance Determination” rule (12 C.F.R. part 370 of the FDIC’s 

Rules and Regulations) requires each IDI with two million or more deposit accounts to configure its IT 

system to calculate the insured and uninsured amount in each deposit account. This requirement will 

assist in the potential resolution of a large institution and ensure the timely payment of insured funds to 

depositors should that become necessary.
74

Any assets not purchased by an assuming institution at the time of resolution are retained in the 

receivership. Various strategies are then used to sell the assets as quickly and efficiently as possible 

consistent with statutory considerations applicable to the disposition of assets. The FDIC is statutorily 

required to conduct operations in a manner which: (1) maximizes the return from the sale; (2) minimizes 

the losses realized; (3) ensures adequate competition and fair and consistent treatment of offerors; 

(4) prohibits discrimination in the treatment of offerors; and (5) maximizes the preservation of the 

availability and affordability of residential real property for LMI individuals.

7

Additionally, FDIC staff identifies and investigates claims against directors, officers, and other 

professionals, and pursues those claims on behalf of the receivership, when the claims are both 

meritorious and expected to be cost-effective. Potential income tax refunds can be another significant 

asset of the receivership, and staff focuses on maximizing refunds and expediting recovery of tax refunds 

from taxing authorities. The FDIC also notifies likely claimants of the failed institution and provides them

with instructions for filing a timely claim in order to ensure that legitimate claims against the receivership 

are satisfied fairly. Valid claims are paid under the priorities set by law. 8 The FDIC terminates the failed 

bank receivership after the disposition of all assets, and the payment of proven claims against the 

receivership.

 7 12 U.S.C. 1821(d)(13)(E).

8 Depositor preference, 12 U.S.C 1821 (d)(11)(A).
75

The following table depicts the strategic goal, strategic objectives, and annual performance goals for the 

Receivership Management Program.

Strategic Goal Strategic Objectives Annual Performance Goals

Resolutions 

are orderly 

and 

receiverships 

are managed 

effectively.

The FDIC manages 

receiverships to 

maximize net 

return and 

terminates them in 

an orderly and 

timely manner.

Value, manage, and market assets 

of failed IDIs and their subsidiaries 

in a timely manner to maximize the 

net return. (5.1-1)

Manage the receivership estate 

and its subsidiaries toward an 

orderly termination. (5.1-2)

The FDIC 

investigates 

potential 

recoveries, 

including claims 

against 

professionals, and 

pursues them if 

deemed to be 

meritorious and 

expected to be 

cost-effective.

Conduct investigations into all 

potential professional liability 

claim areas for all failed IDIs and 

decide as promptly as possible to 

close or pursue each claim, 

considering the size and 

complexity of the institution. (5.2-

1)
76

STRATEGIC GOAL 5:

Resolutions are orderly and receiverships are managed effectively.

STRATEGIC OBJECTIVE 5.1

The FDIC manages receiverships to maximize net return and terminates them in an orderly and timely 

manner.

Annual Performance Goal 5.1-1

Value, manage, and market assets of failed IDIs and their subsidiaries in a timely manner to maximize the

net return.

Indicator and Target

1. Percentage of the assets marketed for each failedIDI 

• Market at least 90 percent of the book value of the institution’s marketable assets 

within 90 days of the failure date for cash sales, 120 days of the date for pools of 

similar assets of appropriate size to bring to market for joint venture, or 180 days for 

assets identified for securitization.

Means and Strategies

Operational Processes (initiatives and strategies): After the resolution of a failed IDI, the FDIC collects and 

manages any remaining assets in a cost-effective manner to maximize recoveries and preserve value 

until the assets can be marketed. The FDIC typically transfers remaining assets to contracted servicers 

who manage such assets until those assets are marketed and sold. The FDIC uses the Standard Asset 

Valuation Estimation (SAVE) methodology, third-party tools, valuation contractors, and financial 

advisors to value most of the assets of a failed IDI and to inform the marketing and disposition plan. The 

failed IDI’s assets are grouped into pools, and potential asset purchasers are given the opportunity to 

view sales information before submitting bids online.
77

Generally, by quickly returning the assets of a failed IDI to the private sector, the FDIC maximizes net 

recoveries and minimizes disruption to the local community. Most of any remaining assets are marketed

within 120 days after an IDI fails. 

The SAVE methodology uses standard assumptions and market information to ensure consistency in the 

valuation of assets. The FDIC also uses third-party tools that are widely accepted by the financial sector 

to develop asset valuations. The process, methodology, and assumptions used to value assets are 

continually reviewed and, when necessary, updated. The FDIC regularly updates and refines its 

marketing strategies to market assets as quickly and efficiently as possible.

Human Resources (staffing and training): For 2024, the FDIC has 426 permanent authorized positions to 

carry out its resolutions and receivership management functions. If resolution activities increase, the 

FDIC adds non-permanent staff to help with the additional workload. In 2024, the FDIC has 

supplemented its permanent resolutions and receivership management workforce with 126 authorized 

non-permanent positions to address the elevated workload associated with the three large regional 

bank failures in early 2023. The FDIC also supplements its workforce with contractor resources. 

Contractors are used, as necessary, to manage and sell the assets of failed IDIs. The FDIC has 

comprehensive policies, procedures, and internal controls that cover every phase of the contracting 

process.

Consistent with the requirements of the Dodd-Frank Act, the FDIC will continue to identify and address 

barriers to the participation of underrepresented groups, including minority- and women-owned 

businesses, law firms, and investors in FDIC contracting and asset purchase opportunities.

Information Technology: The FDIC uses technology extensively to make its asset management/servicing, 

sales strategies, and other business processes more efficient and to keep pace with changing market and 

emerging business practices.
78

Verification and Validation

Progress in meeting this annual performance goal is tracked through established management reporting 

processes.

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and its associated performance indicator are unchanged for 2024.

Annual Performance Goal 5.1-2

Manage the receivership estate and its subsidiaries toward an orderly termination. 

Indicator and Target

1. Timely termination of newreceiverships

• Terminate at least 75 percent of receiverships that were at least two years old and 

were not subject to unresolved loss-share, structured transaction, environmental, 

legal, or tax impediments at the start of the year.

Means and Strategies

Operational Processes (initiatives and strategies): The oversight and prompt termination of a 

receivership preserves value for uninsured depositors and other receivership claimants by reducing 

overhead and other holding costs. Each receivership is monitored on an ongoing basis by staff and a 

receivership oversight committee. The committee meets monthly to review and evaluate the progress 

that has been made in removing the impediments preventing receivership terminations.
79

To be eligible for termination, a receivership must be free of all impediments. These impediments may 

include contractual liabilities, offensive or defensive litigation, potential representation and warranty 

asset sale claims, open employee benefit plans, open subsidiary corporations where articles of 

dissolution have not been approved, and known or potential environmental contamination liabilities.

Once the FDIC has disposed of all of the assets of the receivership, resolved all liabilities, and verified

that no material financial or legal risks remain, a final distribution is made to the creditors and the 

receivership is terminated. During 2023, seven new receiverships were added to the FDIC’s inventory of 

receiverships and 65 were terminated, leaving 74 active receiverships at year-end.

9

Human Resources (staffing and training): Current and projected workloads are continually assessed to 

ensure that adequate staff and contractor resources (if needed) are available to fulfill the FDIC’s 

receivership management responsibilities.

Information Technology: The Receivership Oversight Management System (ROMS) tracks FDIC 

receiverships throughout the termination process and is used to identify impediments to termination, 

track resolution, and initate the termination process.

Verification and Validation

The process of terminating a receivership is tracked in FDIC systems, and monthly termination reports 

are reviewed for accuracy. System users validate data and any discrepancies are reconciled. Results are 

reported through established management reporting processes.

2023 Performance Results

The FDIC successfully met the performance target for this annual performance goal in 2023. This annual 

performance goal and its performance indicator are unchanged for 2024. 

 9 Although there were five bank failures during 2023, two of them were initially resolved through the creation of 

bridge banks. The subsequent dissolution of those bridge banks involved the creation of separate receiverships 

from the original failed bank receiverships.
80

STRATEGIC OBJECTIVE 5.2

The FDIC investigates potential recoveries, including claims against professionals, and pursues them if 

deemed to be meritorious and expected to be cost-effective.

Annual Performance Goal 5.2-1

Conduct investigations into all potential professional liability claim areas for all failed IDIs and decide as 

promptly as possible to close or pursue each claim, considering the size and complexity of the 

institution.

Indicator and Target

1. Percentage of investigated claim areas for which a decision has been made to close or

pursue the claim

• For 80 percent of all claim areas, make a decision to close or pursue professional 

liability claims within 18 months of the failure of an IDI.

Means and Strategies

Operational Processes (initiatives and strategies): The FDIC investigates potential claims against 

professionals (e.g., directors, officers, attorneys, and others) whose actions may have contributed to 

losses at a failed IDI and assesses the viability of recovery sources including liability and fidelity 

insurance policies. Once the investigation is complete, the FDIC determines whether it has viable, costeffective claims and whether it should pursue them. To comply with statute of limitations requirements, 

most professional liability investigations generally must be completed and viable claims filed within 

three years for tort claims and six years for contract claims following an IDI’s failure.

Human Resources (staffing and training): Workload requirements are regularly reassessed to ensure that 

staffing is sufficient to fulfill these responsibilities. The FDIC uses contractor resources (including 

outside legal counsel) and hires non-permanent staff, as needed. 
81

Information Technology: The FDIC Divisional Oversight of Liability Litigation and Restitution System 

(DOLLARS) is used to obtain the status and monitor the pursuit of professional liability claims. The 

system provides the means to track IDI failure dates, potential statute of limitations expiration dates, 

and other pertinent information.

Verification and Validation

Periodic data reviews are conducted to ensure that the information in DOLLARS is current and accurate. 

Progress in meeting this goal is reported through established management reporting processes.

2023 Performance Results

This annual performance goal was not applicable in 2023. Although investigations were initiated for the 

banks that failed in 2023, none of those investigations reached the 18-month target timeframe during 

2023. This annual performance goal and its associated performance indicator and target are unchanged 

for 2024.
82

EFFECTIVE MANAGEMENT OF STRATEGIC RESOURCES

Introduction

Financial Resources Management

Human Capital Management

Management of Information Technology Resources

Enterprise Risk Management and Internal Controls 
83

Introduction

The FDIC recognizes that it must effectively manage many critical strategic resources to successfully 

carry out the annual performance goals outlined in this plan. These resources must be aligned and 

deployed to the areas where they are most needed. An overview of planned 2024 initiatives to enhance 

the FDIC’s management of its key strategic resources is provided below.

Financial Resources Management

The FDIC does not use taxpayer funds. Its operational expenses are predominantly paid from the DIF, 

which is funded from assessments paid by insured financial institutions and income from DIF

investments. The FDIC takes very seriously its fiduciary responsibilities to use these funds efficiently and 

cost-effectively to meet its mission responsibilities. To that end, the FDIC engages annually in a rigorous 

planning and budget formulation process to ensure that budgeted resources are properly aligned with 

workload projections and designated corporate priorities.

The 2024 FDIC Operating Budget is $197 million, 6.3 percent lower than the 2023 FDIC Operating Budget. 

This reduction was attributable to a $475 million decrease in the budget for the receivership funding 

budget component, partially offset by an increase in the ongoing operations budget component. The 

receivership funding budget was decreased for 2024 because most of the projected costs for the three 

large regional bank failures in early 2023 had already been expensed. The ongoing operations budget 

increase was primarily attributable to scheduled salary and benefit increases under the existing 

compensation agreement with the FDIC’s employee union and targeted increases in the number of 

authorized positions for 2024. The 2024 FDIC Operating Budget authorizes 189 new positions, primarily 

to carry out the FDIC’s bank supervision, resolution, and other core mission responsibilities. The 2024 

budget also includes funding for continuation of multi-year IT and facilities modernization efforts. More 

information on the 2024 FDIC Operating Budget is presented in Appendix A.
84

Human Capital Management

The FDIC’s most important resource is the “intellectual capital” that its employees contribute to 

achieving its mission. For that reason, the FDIC strives to be a pre-eminent employer among federal 

agencies. Consistent with that objective and in response to recent media reports of sexual harrasment 

within the FDIC workforce, the FDIC will focus this year on its pursuit of the various initiatives identified 

in the Action Plan for a Safe, Fair and Inclusive Work Environment. Most of those initiatives are targeted 

for completion in 2024. They include an independent third-party review by a respected outside law firm 

of the FDIC’s existing workplace culture, with recommendations for improvement; mandatory in-person

training for all employees, managers, and executives on identifying, addressing, and preventing 

harassment; and completion of a comprehensive review and update of a broad array of current policies, 

procedures, and practices to ensure they support a workplace in which all employees feel safe, valued, 

and respected. The FDIC has no greater priority than addressing these issues.

Strategic Workforce Planning and Readiness

Like many federal agencies, the FDIC faces potential succession management challenges. The FDIC is in 

the midst of a generational transiton in its workforce as many employees who have devoted much of 

their careers to the FDIC have retired or are expected to retire in the near future. Almost 40 percent of 

the FDIC’s current permanent workforce is projected to retire over the next ten years. In response to this 

challenge, the FDIC has expanded its strategic workforce planning and is using targeted strategies to 

reduce the risk of vacancies in key positions at all levels. The FDIC will also ensure that it maintains a 

strong talent pipeline by continuing its efforts to recruit, develop, and retain a highly-skilled, diverse, 

and results-oriented workforce for the future that is prepared to address the challenges of an 

increasingly complex financial system.

A key component of the FDIC’s long-term workforce development strategy continues to be the 

recruitment and retention of examiners. In 2023, the FDIC returned to in-person recruiting, refined its 

recruiting strategies and hiring processes, and began using new technology tools to enhance recruiting 

and reduce hiring times for new, entry-level examiner trainees. A return to on-site bank examinations 

also enhanced the on-the-job training provided to those trainees.
85

Nevertheless, the FDIC currently has a serious imbalance between commissioned and pre-commissioned 

examiners that emerged during the pandemic. In response to that challenge and consistent with the 

statutory requirement to seek to maintain comparability with other federal bank regulatory agencies in 

regard to compensation and benefits, the FDIC substantially enhanced its salaries and benefits in 2023, 

including a significant expansion of the FDIC’s student loan repayment program. These changes should 

enhance the FDIC’s attractiveness to new employees, particularly entry-level employees. In addition, the 

FDIC will implement in 2024 several targeted benefits and incentives to promote retention and create 

new advancement opportunities for commissioned examiners, particularly in high-cost and hard-to-fill 

locations.

In 2024, the FDIC will also continue to pursue several other ongoing initiatives to improve employee 

recruiting and retention. These include the collection and analysis of employee feedback provided 

through the Federal Employee Viewpoint Survey, employee “stay interviews,” exit surveys, and other 

sources; continued enhancement of benefits and rewards that motivate employees to stay with the FDIC 

and apply to managerial positions; and the use of short-term retention incentives to retain retirementeligible employees in select positions to focus on knowledge transfer and employeee development. 

The FDIC is also planning for substantial turnover over the next several years in its current cadre of 

executives and managers. In 2023, the FDIC substantially revised its executive and managerial

classification and compensation systems and streamlined managerial and executive hiring processes to 

make its leadership positions more attractive and reduce hiring time. The FDIC also fully incorporated its

leadership competencies into the managerial and executive selection process. In 2024, the FDIC’s 

Corporate University will begin to incorporate these leadership competencies into FDIC developmental 

programs to build a strong current and future leadership cadre. The FDIC will also begin implementation 

of a formal competency policy adopted in 2023 to guide the development of job-specific technical 

competencies across the organization.
86

Diversity, Equity, Inclusion, and Accessibility

The FDIC continues to demonstrate its commitment to fostering diversity, equity, inclusion, and 

accessibility (DEIA) within the FDIC workforce, in our business practices, and across the financial services 

industry. Initiatives for 2024 will include:

• Continuing to cultivate a diverse, inclusive, and high-performing culture for all divisions 

and offices through strategies that are consistent with agency goals and tailored to 

individual needs and circumstances;

• Developing a new agency-wide DEIA strategic plan; 

• Implementing strategies to address challenges to outreach and recruiting among 

potential applicants with the largest gaps in civilian labor participation force rates in the 

FDIC workforce, based on the fiscal year 2022 MD-715 Report, and supporting strategic 

efforts to reach all available talent in the labor market; 

• Enhancing recruiting and retention of women through the new Female Recruitment and 

Retention Task Force established under the Action Plan.

• Expanding recruiting efforts at minority-serving institutions, including Historically Black 

Colleges and Universities, Hispanic-serving institutions, and various affinity 

organizations; 

• Launching the fourth cycle of the agency’s program to provide support and resources 

geared towards first-generation professionals in the workplace; 

• Launching the fourth cycle of two leadership and career development programs to 

develop a diverse group of participants to serve as the next generation of FDIC leaders; 

• Increasing technical assistance touch points for minority- and women-owned 

businesses and investors interested in doing business with the FDIC; and

• Expanding outreach to bank and professional trade organizations to increase 

participation in Diversity Self-Assessments and strengthen DEIA efforts at financial 

institutions. 
87

Employee Engagement

The FDIC participates in annual employee surveys conducted by the U.S. Office of Personnel 

Management. These surveys provide key insights into employee opinions and perceptions. FDIC 

leadership uses the results to make improvements in employee satisfaction, engagement, and 

organizational performance. Survey results consistently demonstrate that FDIC employees have an 

excellent understanding of the FDIC’s mission and strategic direction, and know how their work fits into 

the organization’s goals and priorities. They believe their work is important, and gain a sense of personal 

accomplishment from it. Employees also have a high degree of confidence in their ability to meet the 

needs of their customers, contribute positively to the agency’s performance, produce high-quality work, 

and adapt to changing priorities.

The FDIC continues to enhance its Workplace Excellence (WE) Program and FDIC-National Treasury 

Employees Union (NTEU) Labor Management Forum (LMF). The FDIC recently launched a WE Leadership 

Committee to serve as a mechanism to share ideas, projects, and best practices from the WE Councils. 

The WE Councils continue to focus on engaging employees in their divisions and recommending 

organizational improvements. The LMF provides NTEU with pre-decisional input on workplace matters 

to the fullest extent practicable, without regard to whether those matters are negotiable subjects of 

bargaining. In addition, FDIC employees have other opportunities to shape organizational culture and 

work processes, and enhance communications and engagement. They can serve as members of the 

Chairman’s Diversity Advisory Councils and Employee Resource Groups, and participate in team 

discussions, listening sessions, and daily employee-supervisor interactions. 

The FDIC will continue to look for meaningful ways to increase employee engagement in 2024. WE 

Leadership Committee meeting frequency will be increased from semi-annual to quarterly, and WE 

Councils will be invited to participate in focus area calls on a quarterly basis. A communication plan to 

increase awareness of WE initiatives and outcomes will be implemented, and WE Councils will utilize 

survey results and other relevant information to develop workplace improvement action plans. The LMF 

will continue to meet quarterly, and as needed, to allow for pre-decisional input from NTEU.
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Employee Learning and Development

The FDIC provides employees with skills-based training and leadership development opportunities to 

help achieve its mission. It completed a multi-year modernization initiative that included expanding 

virtual and online offerings, integrating modern learning technology, and modernizing the Training 

Center. The FDIC is using these investments to prepare employees for the challenges ahead by using a 

blend of delivery modes to provide training when and where it is needed. In 2024, the FDIC will focus on 

researching and implementing strategies and best practices to improve learning and development 

processes to enhance the learner experience. The FDIC will continue to use learning programs as 

opportunities to strengthen its organizational culture, build key competencies, and reinforce corporate 

values.

The FDIC is increasing training offerings to accommodate the large number of new risk management and 

compliance examiner trainees. In addition, the FDIC is implementing a Just-in-Time Training Initiative to 

ensure that examiner courses appropriately align with on-the-job components of examiner development 

so that new examiners are more prepared for the exam tasks they will be assigned. Training and 

readiness activities for resolution and receivership specialists are also maintained to ensure they meet 

up-to-date guidelines and practices. 

The FDIC has a comprehensive leadership development curriculum that consists of core courses, 

electives, and enrichment activities focused on developing employees as leaders at all levels of the 

organization. The FDIC also provides consultative services to managers and delivers customized training 

for teams.

Management of Information Technology Resources 

The FDIC relies on modern and secure IT to achieve its mission. Technology trends like artificial 

intelligence (AI) and Zero Trust (ZT) Architecture have significant potential to transform the FDIC’s core 

business processes to make them more efficient and to strengthen the organization’s cybersecurity and 

privacy posture. 
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The FDIC is committed to providing a robust, resilient, and secure IT environment that supports 

emerging business needs, promotes efficient operations, and improves FDIC engagement with regulated 

institutions and the public. To effectively manage its IT resources, the FDIC will evaluate market 

innovations that can help modernize its portfolio of legacy IT systems, strengthen the IT infrastructure 

that serves its workforce and mission constituents, and implement new core business capabilities.

IT Modernization Plan and Roadmap

The FDIC’s current IT environment is heavily dependent on outdated legacy applications and platforms 

that run in an on-site data center. The FDIC has adopted a multi-year IT Modernization Plan and 

Roadmap that will guide its technology activities and spending priorities for the next several years. In 

2023, the FDIC continued to build out its cloud-based IT-Infrastructure-as-a-Service environment and 

modernize its data management and analytics capabilities. It also migrating its mission-essential and 

mission-critical IT applications and data to target cloud platforms. This multi-year effort will continue in 

2024 and beyond. The ultimate goal of the Cloud Infrastructure Migration Program is to significantly 

improve the resiliency, scalability, and security of the agency’s core computing environment, 

strengthening the FDIC’s ability to manage increased work volume, conduct complex analyses with 

modern tools, and quickly respond to emerging business needs and new technologies. 

In addition, the IT Modernization Program will focus on the modernization of current applications that

rely on aging or obsolete technology. In conjunction with the modernization of these legacy 

applications, FDIC staff will simultaneously streamline and reengineer the underlying business processes 

to take advantage of new automated capabilities and increase efficiency and effectiveness by using Agile 

development methodologies and human-centered design practices. One of the key goals of the plan is 

to establish an IT environment where FDIC employees can perform work unencumbered by limitations 

related to technology, geography, or manual processes. New technology will also be implemented to 

improve the FDIC’s cybersecurity posture to address emerging threats and regulatory needs, and 

controls will be strengthened in the areas of IT governance, contract oversight management, and 

financial management.
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Information Security and Privacy

Cybersecurity risk management will remain a priority as cybersecurity threats proliferate and new 

vulnerabilities are constantly being discovered and mitigated in systems, software, services, and the 

supply chain.

The FDIC continues to build upon the principles set forth in its IT Strategic Plan to mature cybersecurity 

and privacy capabilities and ensure the continued confidentiality, availability, and integrity of FDIC data 

and information systems. In 2023, the FDIC achieved significant milestones in the adoption of ZT

principles to safeguard its operations and the critical data it manages. By advancing foundational ZT

Architecture capabilities, the FDIC continues to improve the enterprise security posture and enhance 

processes and capabilities to provide secure and accurate data access. The FDIC refined its strategies, 

executed pivotal acquisitions, and successfully initiated the implementation of foundational 

capabilities, setting the stage for a ZT-oriented future.

In 2024, the FDIC will continue implementation of its ZT strategy and roadmap and will operationalize a

new incident management solution to help automate the management of and response to cyber 

incidents. The FDIC will also continue in 2024 to mature its privacy risk management activities to 

identify and manage how the FDIC’s operations and systems process personally identifiable information.

Privacy considerations are built into the FDIC’s business operations, policies, processes, technologies, 

and contracts by design to fulfill and anticipate current and future privacy needs.

The agency is active in the leadership of the Federal CIO Council and the Federal Privacy Council. The 

FDIC also collaborates with other agencies to promote best practices through the Federal Privacy 

Council and the Financial Regulator Privacy Community of Practice, and continues to build out 

continuous privacy risk management and monitoring through the use of Privacy Impact Assessments 

and compliance with National Institute of Standards and Technology guidance. 
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Data Management

The FDIC has long recognized that data is one of its most important resources, both for internal use and 

for dissemination to the financial industry and other stakeholders. As part of the IT Modernization Plan 

and Roadmap, the FDIC will strengthen its data governance, while pursuing initiatives to maximize 

efficient data utilization. The effective management of data across the organization is central to fulfilling 

the FDIC’s supervisory, insurance, and resolution functions. Managing and governing FDIC data as a 

corporate resource is fundamental to empowering FDIC staff at all levels of the organization to perform 

analysis, support operations, and conduct research that enables sound, evidence-based decisionmaking. This includes the responsible use of AI. In 2023, the FDIC established an AI governance 

framework for the agency. In 2024, the FDIC will continue to ensure responsible stewardship of its data 

by establishing and implementing appropriate data governance requirements for managing data in the 

cloud. The FDIC will also develop and maintain an inventory and catalog of all FDIC data used 

throughout the cloud data lifecycle. 

Technology and Innovation

The FDIC continuously monitors developments in technology to further advance the mission of the FDIC 

and better understand how emerging technology may affect the financial industry. The FDIC continues 

to test the potential application of new and emerging technologies to enhance its business processes 

and accomplish its core mission responsibilities. The FDIC Tech Lab under the CIO plays a leadership 

role in supporting the identification, testing, and adoption of innovative new technologies. It engages

with stakeholders throughout the FDIC on an ongoing basis to identify problems and challenges in 

programs and operations and conducts proofs of concept aimed at removing barriers and building IT 

capabilities.

In 2024, the FDIC will continue to explore the potential application of new and emerging technologies by:

• Exploring the utility and application of robotic process automation and AI to reduce staff burden 

by automating labor intensive manual work; and

• Developing potential use cases that allow employees to learn about distributed ledger 

technologies through hands-on experience.
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Enterprise Risk Management and Internal Controls

As an integral part of its stewardship of the DIF, the FDIC maintains a comprehensive risk management 

and internal control program designed to identify and mitigate enterprise risks and improve the 

efficiency, effectiveness, and control of internal operations. Enterprise Risk Management (ERM) is a way 

to identify, prioritize, and manage risk across the corporation. The FDIC’s ERM program aims to address 

the full spectrum of significant internal and external risks facing the agency and the combined impact of 

those risks as an interrelated portfolio.

In 2024, the FDIC will continue to identify and implement risk-mitigation activities to address risks in the 

FDIC’s Corporate Risk Inventory, enhance the ERM program with active collaboration among all FDIC 

divisions and offices, and perform management-directed or self-initiated program evaluation work. The 

FDIC will also continue to deliver corporate-wide ERM training and report to the Chairman, Operating 

Committee, and Audit Committee on a periodic basis.

The FDIC’s internal control program includes the plans, methods, policies, and procedures that provide 

reasonable assurance that management’s objectives are achieved, operations are effective and efficient, 

reporting is reliable for internal and external use, and that the FDIC follows applicable laws and 

regulations. In 2024, the FDIC will continue to ensure that key financial operations and processes 

maintain sound internal controls, operations are appropriately managed, and opportunities to improve 

the control environment are identified and implemented in an efficient and timely manner. The FDIC 

anticipates focusing on testing and, where appropriate, enhancing controls related to information 

security management, contractor oversight, succession management, supply chain risk management, 

systems development, and model risk management.

The FDIC will continue to review samples of transactions and invoices to confirm management 

attestations regarding financial reporting and internal control procedures. The FDIC will also continue 

to develop process maps for critical operations and enhance data mining capabilities to monitor 

exposure to improper payments. All of these efforts help to ensure that the internal control environment

remains strong throughout the FDIC.
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APPENDICES

Appendix A: Program Resource Requirements

Appendix B: Program Evaluation

Appendix C: Interagency Relationships

Appendix D: External Factors

Appendix E: Organizational Chart
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APPENDIX A

Program Resource Requirements

The chart below breaks out the 2024 FDIC Operating Budget by the FDIC’s three major program areas: 

insurance, supervision, and receivership management. It shows the budgetary resources that the FDIC 

estimates it will spend on these programs during 2024 to pursue the strategic and annual performance 

goals and objectives outlined in this plan, and to carry out other program-related activities. The 

estimates include each program’s share of common support services that are provided on a 

consolidated basis.

Supervision $1,448,190,386

Insurance $447,191,714

Receivership Management $681,152,942

Corporate Expenses $384,999,489

Total $2,961,534,531

In addition, the FDIC has a total authorized 2024 staffing level of 6,817 full-time equivalent positions 

(6,486 permanent, 331 non-permanent).
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APPENDIX B

Program Evaluation

The Office of Risk Management and Internal Controls performs management-directed or selfinitiated evaluation work of FDIC programs to ensure that programs are accomplishing intended

objectives. Program evaluations are collaborative efforts that may involve management and 

staff from multiple divisions and offices. Division and office directors use the results of program 

evaluations to support their annual assertions to the Chairman that operations are efficient and 

effective, financial data and reporting are reliable, laws and regulations are followed, and 

internal controls are adequate (i.e., annual assurance statements).

In 2024, the FDIC will continue to identify opportunities to perform program evaluations to 

mitigate risks to division and office operations and identify opportunities for program 

improvements.
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APPENDIX C

Interagency Relationships

The FDIC has productive working relationships with agencies at the federal, state, and international 

levels. It leverages those relationships to achieve the goals outlined in this plan and to promote stability 

and public confidence in the nation’s financial system. Listed below are examples of the many 

important relationships the FDIC has built with other agencies and entities, seeking to promote strength, 

stability, and confidence in the financial services industry.

Other Federal Financial Institution Regulatory Agencies

The FDIC works closely with other federal financial institution regulators—principally the FRB and OCC—

to address issues and programs that transcend the jurisdiction of each agency. Regulations are, in many 

cases, interagency efforts. For example, interagency rules have been developed to address 

implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act, Basel III,

revisions to risk-based and leverage capital requirements, quantitative liquidity ratios, credit risk 

retention, appraisals, and Call Reports. In addition, the Comptroller of the Currency is a member of the 

FDIC Board of Directors, which facilitates cross-cutting policy development and consistent regulatory 

practices between the FDIC and OCC. The FDIC also works closely with the NCUA, which supervises and 

insures credit unions.

The FDIC also works closely with the Consumer Financial Protection Bureau (CFPB) to address consumer 

protection issues. Under the Dodd-Frank Act, the CFPB has interpretative authority over an enumerated 

list of designated consumer financial laws. As a result, the CFPB is responsible for issuing rules and 

regulations regarding these consumer financial laws; however, the CFPB is required to consult with the 

FDIC, FRB, and OCC on these matters. Supervisory examination and enforcement jurisdiction for the 

designated consumer financial laws for insured, state nonmember banks with assets of $10 billion or less

remains with the FDIC.
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The FDIC retains examination and enforcement jurisdiction for the non-transferred consumer laws (such 

as for the CRA, the Fair Housing Act, and the Federal Trade Commission Act) for insured, state 

nonmember banks with more than $10 billion in assets. The CFPB Director is also a member of the FDIC 

Board of Directors, which facilitates cross-cutting policy development and consistent regulatory 

practices among the FDIC, CFPB, and OCC.

The FDIC, FRB, and OCC also work closely with the Conference of State Bank Supervisors (CSBS), which 

represents the state regulatory authorities, and individual state regulatory agencies. The FDIC also 

collaborates with the Federal Housing Finance Agency (FHFA), which is the rule-writer and supervisor for 

the government-sponsored enterprises and the Federal Home Loan Banks. Finally, the FDIC coordinates 

with the SEC and CFTC on issues such as CCP resolution planning.

Federal Financial Institutions Examination Council (FFIEC)

The FFIEC is a formal interagency body empowered to prescribe uniform principles, standards, and 

report forms for the federal examination of financial institutions and to make recommendations to 

promote uniformity in the supervision of financial institutions. The member agencies of the FFIEC are 

the FDIC, FRB, OCC, NCUA, and CFPB. In addition, the Chair of the FFIEC State Liaison Committee serves 

as a member of the FFIEC (the State Liaison Committee is composed of five representatives of state 

supervisory agencies). 

To foster interagency cooperation, the FFIEC has established interagency task forces on consumer 

compliance, examiner education, information sharing, regulatory reports, surveillance systems, and 

supervision. The FFIEC has statutory responsibilities to facilitate public access to data that depository 

institutions must disclose under the Home Mortgage Disclosure Act of 1975 (HMDA) and the aggregation

of annual HMDA data for each metropolitan statistical area. It also publishes handbooks, catalogs, and 

databases that provide uniform guidance and information to promote a consistent examination process 

among the agencies and make information available to the public. 
98

This includes maintenance of a central data repository for CRA ratings and public evaluations. The FFIEC 

also provides an online Consumer Help Center that connects consumers with the appropriate federal 

regulator for a particular financial institution.

State Banking Departments

The FDIC, FRB, and OCC work with the CSBS and with individual state regulatory agencies to make the 

bank examination process more efficient and uniform. In most states, alternating examination 

programs reduce the number of examinations that are conducted at insured financial institutions, 

thereby reducing regulatory burden. Joint examinations of larger financial institutions also optimize the 

use of state and FDIC resources in the examination of large, complex, and problem state nonmember 

banks and state-chartered thrift institutions.

Basel Committee on Banking Supervision (BCBS)

The FDIC is a member of the BCBS, a forum for international cooperation on matters relating to financial 

institution supervision, and on numerous subcommittees of the BCBS. The BCBS aims to improve the 

consistency of capital regulations internationally, ensure that the regulatory capital framework for 

internationallyactive institutions is risk-sensitive and includes appropriate constraints on the use of 

financial leverage, and promote enhanced risk management practices among large, internationally 

active banking organizations. Other areas of significant focus include liquidity and funds management, 

market risk exposure, and derivatives activities. 

The FDIC and the other federal banking agencies have worked closely with the BCBS to improve the 

Basel III Capital Accord to strengthen the resiliency of the banking sector and improve liquidity risk

management.
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International Colleges of Regulators

The FDIC participates in several groups of international regulators to address international consistency 

in the implementation of over-the-counter (OTC) derivatives reforms. The OTC Derivatives Regulators’ 

Forum is a college of regulators that discuss initiatives on derivative reforms mandated by the G-2010 and 

FSB.

The group is heavily involved in assuring international consistency on the development of trade 

repositories and CCP clearing. It makes recommendations to standing committees, including the 

Committee on Payment and Settlement Systems, International Organization of Securities Commissions, 

BCBS, and FSB, for rulemakings.

The OTC Supervisors’ Group is primarily involved in changing the infrastructure of the largest dealer 

banks. The group is composed of supervisors of the GSIBs. Current efforts are focused on data 

repositories, dispute resolution, and client clearing. The group obtains commitments from the dealer 

community to make recommended changes and monitors implementation.

Interagency Country Exposure Review Committee (ICERC)

The ICERC was established by the FDIC, FRB, and OCC to ensure consistent treatment of the transfer risk 

associated with the exposure of banks to both public- and private-sector entities outside the United 

States. The ICERC assigns ratings based on its assessment of the degree of transfer risk inherent in U.S. 

banks’ foreign exposure.

 10 The Group of 20 is a group of leading developed and developing nations. Members include the African Union, the 

European Union, and Argentina, Australia, Brazil, Canada, China, France, Germany, India, Indonesia, Italy, Japan, 

Mexico, Russia, Saudi Arabia, South Africa, South Korea, Turkey, the United Kingdom, and the United States.
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International Association of Deposit Insurers (IADI)

The FDIC has played a leading role in developing IADI into a global standard setter and the world’s 

premier provider of technical assistance and training for deposit insurance since the association was 

formed in 2002. IADI contributes to the stability of the global financial system by promoting 

international cooperation in the field of deposit insurance. Through IADI, the FDIC builds strong bilateral 

and multilateral relationships with foreign deposit insurers, resolution authorities, and international 

organizations. The FDIC also provides technical assistance and conducts outreach activities with foreign 

entities to help develop and maintain sound banking and deposit insurance systems.

Association of Supervisors of Banks of the Americas (ASBA)

The FDIC plays a leadership role in ASBA and participates in the organization’s activities. ASBA develops, 

disseminates, and promotes sound bank supervisory practices and resilient financial systems 

throughout the Americas and the Caribbean in line with international standards. The FDIC supports the 

organization’s mission and activities by contributing to ASBA research and guidance initiatives, technical 

training and cooperative endeavors, and leadership building programs.

Shared National Credit Program

The FDIC participates with the other federal financial institution regulatory agencies in the Shared 

National Credit Program, an interagency program that performs a uniform credit review twice annually 

of financial institution loans that exceed $100 million and are shared by three or more financial 

institutions. The results of these reviews are used to identify trends in industry sectors and the credit 

risk management practices of banks.
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The reviews are published in December of each year and include findings from both semiannual reviews 

to help the industry better understand economic and credit risk management trends. 

Joint Agency Task Force on Discrimination in Lending

The FDIC participates on the Joint Agency Task Force on Discrimination in Lending with several other 

federal financial institution regulators (i.e., the FRB, OCC, and NCUA) along with the CFPB, the 

Department of Housing and Urban Development, the FHFA, the Department of Justice, and the Federal 

Trade Commission (FTC). The agencies exchange information about fair lending issues, examination and 

investigation techniques, and interpretations of statutes, regulations, and case precedents.

European Forum of Deposit Insurers

The FDIC and the European Forum of Deposit Insurers share similar interests, and the FDIC supports the 

organization’s mission to contribute to the stability of financial systems by promoting European 

cooperation in the field of deposit insurance. The FDIC openly shares its expertise and experience in 

deposit insurance and failed bank resolution through discussions and exchanges on issues that are of 

mutual interest and concern (e.g., cross-border issues, bilateral and multilateral relations, and customer 

protection).

Financial and Banking Information Infrastructure Committee (FBIIC)

The FDIC works with the Department of Homeland Security and the Office of Cyberspace Security 

through the FBIIC on operational and tactical issues related to critical infrastructure matters and 

cybersecurity in the financial services industry. The FBIIC was chartered under the President’s Working 

Group on Financial Markets and is charged with improving coordination and communication among 

financial regulators, promoting public-private partnerships within the financial sector, and enhancing 

the resiliency of the financial sector overall. Other federal government members of the FBIIC include the 

CFPB, FHFA, FRB, NCUA, OCC, CFTC, SEC, Department of the Treasury, and the Farm Credit 

Administration. 
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Bank Secrecy Act (BSA), Anti- Money Laundering (AML), Counter-Financing of Terrorism (CFT), and 

Anti-Fraud Working Groups

The FDIC participates in several interagency, public-private, and intergovernmental groups, described 

below, to help combat money laundering, terrorist financing, and fraud.

• The BSA Advisory Group is a public/private partnership of agenciesand 

organizations that meets to discuss strategies and industry efforts to address money 

laundering, terrorist financing, and other illicit financial activities. Areas of focus 

include: rulemaking related to the BSA/AML Compliance Program, Customer 

Identification Program requirements, and suspicious activity reporting 

requirements; a possible pilot examination program to evaluate potential changes 

to the referenced rules; innovative approaches to suspicious activity and currency 

transaction filing requirements; vendor-developed technology to help meet BSA 

compliance requirements, including suspicious activity monitoring; and other 

emerging risks.

• The FFIEC AML/CFT Subcommittee, in consultation with the Financial Crimes 

Enforcement Network (FinCEN), coordinates AML/CFT policy matters and training, 

and works to improve communications among the agencies. The AML/CFT 

Subcommittee builds on existing activities and works to strengthen the ongoing 

initiatives of other formal and informal interagency groups that oversee various 

AML/CFT issues. This working group meets monthly and invites other agencies, such 

as the SEC, CFTC, Treasury, Internal Revenue Service (IRS), and OFAC, on a quarterly 

basis to ensure broader coordination of AML/CFT and sanctions efforts.

• The Basel AML/CFT Expert Group is responsible for monitoring AML/CFT issues that 

have a bearing on banking supervision, coordinating with the FSB, and serving as a 

forum for AML/CFT experts from banking supervisory agencies.

• The Financial Action Task Force (FATF) is an intergovernmental body that sets 

standards and promotes effective implementation of legal, regulatory, and 

operational measures for combating money laundering, terrorist financing, and 

other related threats to the integrity of the international financial system.
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• The Fraud Risk-Management Interagency Working Group is composed of 

representatives from the federal banking agencies to strengthen relationships and 

better understand the fraud threat environment for depository institutions. The 

group also provides a forum for developing consistent interagency programs for 

combating financial institution fraud.

Financial Literacy and Education Commission (FLEC)

The FDIC is a member of the Financial Literacy and Education Commission (FLEC), which was 

established by the Fair and Accurate Credit Transactions Act of 2003. The FDIC actively supports FLEC’s 

efforts to improve financial literacy in America by assigning experienced staff to provide leadership and 

support for FLEC initiatives, including updates to the National Strategy on Financial Literacy and various 

FLEC working groups.

Financial Education Partnerships

The FDIC collaborates with other federal, state, and local government agencies to promote financial 

education, capability initiatives, and fraud prevention for consumers and small businesses. These 

include the CFPB, US Small Business Administration (SBA), FTC, Institute of Museum and Library Services 

(IMLS), and other federal and state agencies. The FDIC also promotes initiatives combining youth and 

young adult accounts and financial education through collaboration with local financial institutions, 

governmental entities, workforce development and education organizations, and other nonprofit 

organizations.

Alliance for Economic Inclusion (AEI)

The FDIC established and leads the AEI, a national initiative to bring unbanked and underbanked 

populations into the financial mainstream. The AEI is composed of broad-based coalitions of financial 

institutions, community-based organizations, and other partners in 14 markets across the country. 

These coalitions work to increase banking services for underserved consumers in LMI neighborhoods, 

minority and immigrant communities, and rural areas.
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These services include savings accounts, affordable remittance products, targeted financial education 

programs, small-dollar loan programs, alternative delivery channels, and other asset-building programs.

U.S. Small Business Administration (SBA) Strategic Alliance Memorandum (SAM)

The FDIC partners with the SBA to encourage financial institutions to prudently serve entrepreneurs and 

small business owners. Through a SAM, the FDIC and SBA collaborate by co-sponsoring events and 

activities to help banks become fully aware of SBA capital access programs and connect banks to 

opportunities to address small business training, counseling, and financial service needs.

Financial Stability Board (FSB)

The FDIC actively participates in the work of the FSB, an international body established by the G-20 

leaders in 2009. As a member of the FSB ReSG and its Cross-Border Crisis Management subgroups 

(CBCMs) for banks, insurers, and financial market infrastructures, the FDIC has helped to develop 

international standards and guidance on issues relating to the resolution of G-SIFIs. Much of this work 

has related to the operationalization of the FSB Key Attributes of Effective Resolution Regimes for 

Financial Institutions and supporting work to monitor standards implementation. The FDIC currently

chairs the ReSG and co-chairs the CBCM for financial market infrastructures.

Federal Trade Commission (FTC), National Association of Insurance Commissioners (NAIC), and the 

Securities and Exchange Commission (SEC)

The Gramm-Leach-Bliley Act (GLBA), which was enacted in 1999, permits insured financial institutions to 

expand the products they offer to include insurance and securities. GLBA also includes increased 

security requirements and disclosures to protect consumer privacy. The FDIC and other FFIEC agencies 

coordinate with the FTC, SEC, and NAIC to develop industry research and guidelines relating to these 

products.

GLBA also requires the SEC to consult and coordinate with the appropriate federal banking agencies on 

certain loan-loss allowance matters involving public bank and thrift holding companies.
105

The SEC and the agencies have an established consultation process designed to fully comply with this 

requirement while avoiding unnecessary delays in processing holding company filings with the SEC and 

providing these institutions access to the securities markets.

In addition, the accounting policy staffs of the FDIC and the other FFIEC agencies and the SEC’s Office of 

the Chief Accountant (OCA) meet quarterly to discuss accounting matters of mutual interest and 

maintain ongoing communications on accounting issues relevant to financial institutions. Other 

meetings are held with the OCA, as necessary, either on an individual agency or interagency basis.

Internal Revenue Service (IRS)

The FDIC works with high-ranking officials at the IRS primarily to simplify the failed bank receivership 

federal tax filing process and to ensure efficient audit examinations. Gaining a mutual understanding of 

each agency’s tax compliance procedures has reduced the amount of resources needed to accurately 

process and file timely receivership federal tax returns. Similarly, establishing joint federal tax audit 

procedures has increased uniformity and significantly reduced regulatory burden for both agencies.

Ongoing collaboration with the IRS also remediates ad-hoc, unintended tax consequences that arise 

during a bank failure, such as protecting the depositors’ interests in the event of a payout of Individual 

Retirement Arrangement (IRA) accounts.

Financial Stability Oversight Council (FSOC)

The FDIC works closely with the FSOC and its member agencies, including the FRB, CFTC, FHFA, NCUA, 

OCC, SEC, Treasury, and CFPB, in carrying out the FSOC’s responsibility for identifying risks to the 

financial stability of the United States, promoting market discipline, and responding to emerging risks to 

the stability of the U.S. financial system. The FDIC Chairman is one of ten voting members, along with 

the Secretary of the Treasury, the heads of the other federal financial regulators, and an independent 

insurance expert.
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President’s Working Group (PWG) on Financial Markets

The PWG conducts various studies regarding financial markets. The PWG is chaired by the Secretary of 

the Treasury and its member agencies, including the FRB, SEC, and CFTC. While not a member of the 

PWG, the FDIC convenes for relevant sessions and may participate as appropriate in preparing analyses 

relevant to the U.S. financial system. 

Network of Central Banks and Supervisors for Greening the Financial System (NGFS)

The FDIC is engaged with NGFS to foster collaboration and share best practices in addressing climaterelated financial risks on a global basis. The NGFS is not a standard-setting body. Rather, it is a forum 

for voluntary collaboration and information sharing among central banks and banking supervisors. To 

the extent that other jurisdictions have different mandates with respect to climate-related matters, the 

FDIC has remained, and will continue to remain, strictly within its mandate.
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APPENDIX D

External Factors: The Economy and Its Impact on the 

Banking Industry and the FDIC

Economic conditions at the national, regional, and local levels affect banking strategies and the banking 

industry’s overall performance. Business and household activity tends to be cyclical and influences loan 

growth and credit performance for the banking industry. Business conditions and macroeconomic 

policies combine to determine the rate of inflation, domestic interest rates, equity market valuations, 

and the exchange value of the dollar. These, in turn, influence the lending, funding, and off-balancesheet activities of IDIs.

U.S. economic conditions were solid in 2023, with improving economic growth and slowing inflation. 

Consumer spending, business fixed investment, and government spending improved in 2023, while 

residential investment declined. Full-year real gross domestic product growth improved in 2023 to 

roughly 2019 levels. Labor market conditions slowed in 2023 but remained strong. The unemployment 

rate was near historically low levels, and payroll gains, although slowing, were above the pre-pandemic 

pace. Inflation declined, but the pace of the decline slowed in the second half of the year. Inflation 

remained above the Federal Reserve’s two-percent target, and monetary policy continued to tighten in 

2023. The Federal Reserve increased the federal funds rate four times in the first half of the year, but 

paused rate increases from September to December. It continued to reduce its holdings of Treasury 

securities and agency debt and agency mortgage-backed securities. Financial market conditions 

tightened after the bank failures in March and May, but eased later in the year. 

Several factors weigh on the economic outlook in 2024, including the effects of elevated inflation and 

interest rates, continued geopolitical uncertainty, and slowing global growth. The Blue Chip consensus 

expects growth to slow in 2024, but the outlook has improved in recent months. Weaker economic 

conditions could challenge banking conditions as they could lead to reduced loan demand, potential 

credit strains, and reduced banking sector profitability.
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The banking industry has proven resilient despite large bank failures that occurred in the spring of 2023. 

The 4,587 FDIC-insured commercial banks and savings institutions that filed financial results in fourth

quarter 2023 reported aggregate net income of $38.4 billion for the three months ended December 31, a 

decline of $30 billion (43.9 percent) from the prior quarter. Higher noninterest expense (up $26.6 billion, 

or 18.9 percent), lower noninterest income (down $6.5 billion, or 8.8 percent), and higher provision 

expense (up $5.2 billion, or 26.5 percent) drove the decline in net income. However, it is estimated that 

70 percent of the decrease in net income was caused by specific, nonrecurring, noninterest expenses at 

large banks.11 These expenses include the special assessment, goodwill amortization, and legal, 

reorganization, and other one-time costs. 

Net operating revenue (net interest income plus noninterest income) was $242.2 billion in the fourth 

quarter 2023, down $7.1 billion (2.9 percent) from the third quarter. While net interest income and 

noninterest income both fell, the decline in noninterest income drove the overall decline. The largest 

contributors to the decline in noninterest income were “all other noninterest income” (down $2.6 

billion, or 7.5 percent), servicing fees (down $2.4 billion, or 75.7 percent), and trading revenue (down 

$1.5 billion, or 11.3 percent).12 Net interest income decreased $0.6 billion (0.4 percent) to $174.6 billion.

 

The net interest margin (NIM) declined 2 basis points to 3.28 percent in the fourth quarter 2023. NIM 

declined as the increase in deposit and non-deposit liability costs more than outpaced the increase in 

asset yields. Despite the quarterly decline, the industry NIM remained 3 basis points above the prepandemic average NIM of 3.25 percent.

Asset quality indicators for the banking industry remained favorable during the fourth quarter 2023, 

despite pockets of deterioration. Noncurrent loans—loans that are 90 days or more past due or in 

nonaccrual status—increased to 0.86 percent of total loans, up 4 basis point from the prior quarter. The 

share of total loans that were 30–89 days past due increased to 0.61 percent, up 7 basis points from the 

prior quarter. Each delinquency rate remained below its pre-pandemic average of 1.28 percent for 

noncurrent loans and 0.66 percent for loans 30–89 days past due.

 11 After taking into account the estimated tax benefits of the expenses.

12 All other noninterest income includes material write-in items as well as income related to wire transfers and ATM 

fees, bank card and credit card interchange fees, safe deposit box rent, printing and sale of checks, earnings 

on/increase in value of cash surrender value of life insurance, and other noninterest sources.
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Credit card and nonfarm nonresidential commercial real estate loans drove the quarterly increase in the 

noncurrent rate, while residential mortgages drove the quarterly increase in the share of loans 30–89 

days past due.

The industry’s net charge-off rate increased 14 basis points from the prior quarter and 29 basis points 

from the prior year to 0.65 percent, and at year-end 2023, was 17 basis points above its pre-pandemic 

average. Credit card loans led the annual increase in net charge-off balances. The net charge-off rate on 

credit card loans was 4.15 percent, the highest rate reported by the industry since first quarter 2012. 

Total assets increased $259.9 billion (1.1 percent) from third quarter 2023. Nearly three-quarters of all 

banks reported quarterly asset growth. Higher cash balances (up $143.2 billion, or 5.3 percent) and 

securities holdings (up $131.1 billion, or 2.5 percent) led the increase, while lower levels of trading assets 

(down $98.7 billion, or 11.5 percent) partially offset the growth. The increase in securities holdings 

resulted from both portfolio growth and improvement in the fair value of securities already owned.

Total loan and lease balances grew $107.5 billion (0.9 percent) from the previous quarter. This was the 

highest loan growth rate reported by the industry in 2023. An increase in credit card loans (up $63.1 

billion, or 6 percent) drove quarterly loan growth. About three-quarters of banks (75.5 percent) reported 

quarterly loan growth. 

Domestic deposits increased 186.9 billion (1.1 percent) from third quarter 2023, the first quarterly 

increase in domestic deposits in the past seven quarters. Growth in time deposits led the increase in 

domestic deposits, while noninterest-bearing deposits declined for the seventh consecutive quarter. 

Estimated insured deposits (up $46.6 billion, or 0.4 percent) increased during the quarter. Reported 

uninsured deposits decreased during the quarter but would have increased for the first time in seven 

quarters had a large bank’s subsidiary transactions not affected reported data. Excluding that bank 

from the calculations, the industry’s uninsured deposits increased $92.4 billion, or 1.4 percent, in the 

quarter. 
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The number of banks on the Problem Bank list (i.e., institutions with financial, operational, or 

managerial weaknesses that potentially threaten their viability) increased from 44 in the third quarter to 

52 banks at year end 2023, while total assets held by problem banks increased from $53.5 billion to $66.3 

billion. The number of problem banks represent 1.1 percent of total banks, which is near the low end of 

the “normal” range for non-crisis periods of one to two percent of all banks.

One bank opened, and one bank failed during the fourth quarter 2023. The DIF balance was $121.8

billion as of December 31, 2023, $6.4 billion below the balance reported on December 31, 2022. The DIF

reserve ratio, or the ratio of the fund balance to estimated insured deposits, stood at 1.15 percent as of 

December 31, 2023.
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APPENDIX E 

Organizational Chart

A current listing of the FDIC Board of Directors and Senior Executives can also be found on the FDIC’s public website at 

https://www.fdic.gov/about/leadership/index.html.