FDIC Adopts Two-Phase Review Process for Deposit Insurance Applications
The FDIC adopted a two-phase review process for federal deposit insurance applications to provide organizers of proposed depository institutions with a timelier and more predictable path to approval.
In the Financial Institution Letter, the FDIC stated the new procedures are intended to help promote the vitality of the banking industry and accelerate the review process. Under the first phase, which spans 120 days from the receipt of an application, the FDIC reviews the applicant's business plan, financial projections, and proposed leadership. If the initial requirements are satisfied, the agency issues a contingent authorization detailing all pre-opening conditions. This initial phase is designed to give organizing groups clarity before they expend significant resources on capital raising, staffing, and infrastructure development.
The second phase spans up to 12 months following the contingent authorization. During this organizational phase, applicants must submit supplemental materials, including final organizational documents, employment agreements, and risk management policies. The FDIC issues a final approval and deposit insurance order at the end of Phase 2. A pre-opening examination and issuance of the deposit insurance certificate follow. The agency noted that applicants generally can file concurrently with both the FDIC and the relevant chartering authority, and that it would coordinate with chartering authorities throughout the process to avoid duplication.
The two-phase approach applies to all federal deposit insurance applications received after August 15, 2026.