Which institutions need to report their Iowa public funds and total capital? When are they required to report?Reporting to the Superintendent of Banking must be done each quarter, 10 days after the call reports are due. State-chartered banks do not need to report separately, since the information is retrieved from the call reports. However, all national banks, savings and loans, and out-of-state institutions with offices in Iowa must report to the Superintendent via the Iowa Division of Banking web site., How do institutions report their Iowa public funds and total capital to the Superintendent of Banking?The information needed for Iowa state-chartered banks is retrieved automatically from the call reports. State banks do not need to submit the information separately.All national banks, savings and loans, and out-of-state institutions that operate offices in Iowa must submit the information to the Superintendent quarterly. The required information is to be submitted electronically via our Public Funds web site by clicking on “Electronic Submission.” Access is provided by using the institution’s user name and password.The appropriate pledging and custodial forms can be obtained from the State Treasurer’s web site., Are banks required to monitor circumstances (balance levels) on a daily basis?Iowa Code Chapter 12C.22(2) and IAC 781-13.7(1) apply. Iowa Code Chapter 12C.22(2) states “The amount of the collateral required to be pledged by a bank shall at all times equal or exceed the total of the amount by which the public funds deposits in the bank exceeds the total capital of the bank.” Likewise, the rules state in 781-13.7(1) “A pledging bank shall pledge and maintain eligible collateral with the treasurer’s approved custodian by which the market value at all time equals or exceeds the amount by which the public funds deposits in the pledging bank exceed the total capital of the pledging bank.”Eligible collateral must be maintained at all times, not just at quarter end., Are there any exceptions for short term, large dollar deposits?A bank posed this scenario – they have the County Treasurer account, which means that approximately $35 million flows in on a semi-annual basis. Roughly half of those funds are paid out to taxing bodies on the 15th of the month following and the remainder in another 30 days. It is not practical for the bank to pledge $35-40 million given the bank’s investment portfolio and short-term nature of the deposits. The bank is trying to plan ahead with regard to discussion with the County Treasurer.The law is very specific about this situation. Iowa Code chapter 12C.22(2) states “The amount of the collateral required to be pledged by a bank shall at all times equal or exceed the total of the amount by which the public funds deposits in the bank exceeds the total capital of the bank.” Likewise, the rules state in 781-13.7(1) “A pledging bank shall pledge and maintain eligible collateral with the treasurer’s approved custodian by which the market value at all time equals or exceeds the amount by which the public funds deposits in the pledging bank exceed the total capital of the pledging bank.”There are no exceptions for short term, large dollar deposits., How should banks calculate their “total capital”? Is it based on their balance sheet capital or risk based capital?The formula for banks and savings and loans is in Iowa Code Chapter 12C.22(2). “Total capital of the bank means its tier one capital plus both of the following components of tier two capital: a. qualifying subordinated debt and redeemable preferred stock; b. cumulative perpetual preferred stock.”The formula for an out-of-state bank that operates a branch in Iowa is located in Iowa Code chapter 12C.22(3) a through g.You may use these forms:► Public Funds Report - National Banks► Public Funds Report - Savings & Loans► Public Funds Report - Out of State Banks with Iowa OfficesInstitutions need to develop their own internal system to track public deposits in excess of total capital on a daily basis., Would a bank need to pledge for deposits containing public funds from outside the state of Iowa?Iowa Code 12C applies only to Iowa public funds; therefore, the bank would not need to pledge for a deposit from an out-of-state public body to comply with Iowa Code 12C. However, the bank would need to comply with any laws which may apply to public deposits in another state.For purposes of pledging, public funds and public deposits mean the monies of Iowa or a political subdivision or instrumentality of Iowa . See Iowa Code Chapter 12C.2(e) and Iowa Administrative Rules 781-13.2 for definitions of public funds and public units for their complete definitions.Unfortunately, the call reports do not specify Iowa public deposits; therefore, the information that is retrieved from the call reports will include all public deposits, in Iowa and out-of-state., How is FDIC Deposit Insurance handled in the calculation of required collateral?No provisions in the law were made for FDIC insurance. Therefore, total public deposits are used. The FDIC insured amount of each depositor is NOT deducted from the total public funds., Which insurance companies have been approved to provide deposit guaranty bonds?Deposit guaranty bonds for public funds accounts are allowed in Section 12C.22(6)(e) of the Code of Iowa. Over the last several years market conditions have changed with this insurance product. If a bank is considering using this insurance product to secure Iowa Public Funds, please contact the Superintendent of Banking., Can a bank use CDRS for Iowa public fund deposits?Effective July 1, 2006, Chapters 12B and 12C of the Iowa Code were amended to permit banks to use the CDRS program for Iowa public funds, regardless of the location of the other institutions that might receive the deposits. These deposits are not considered public deposits when determining how much a bank must pledge. However, if the Treasurer has to make a sinking fund assessment, the CDRS deposits are included in determining the sinking fund assessment., Can an institution use bank owned time certificates of deposit as collateral for public funds deposits?Effective July 1, 2012 House File 2168 changed Iowa Code 12C 22(6-f) to allow institutions to pledge bank owned time certificates of deposit.House File 2168 effective July 1, 2012: Section 12C.22, subsection 6, Code 2011, is amended by adding the following new paragraph: NEW PARAGRAPH . f. Certificates of deposit issued by a federal deposit insurance corporation insured bank, the payment of which is fully insured by the federal deposit insurance corporation both as to principal and accrued interest, and that have been assigned a committee on uniform security identification procedures number and deposited for the account of the public funds depository bank at the depository trust company.

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Which institutions need to report their Iowa public funds and total capital? When are they required to report?Reporting to the Superintendent of Banking must be done each quarter, 10 days after the call reports are due. State-chartered banks do not need to report separately, since the information is retrieved from the call reports. However, all national banks, savings and loans, and out-of-state institutions with offices in Iowa must report to the Superintendent via the Iowa Division of Banking web site.,  How do institutions report their Iowa public funds and total capital to the Superintendent of Banking?The information needed for Iowa state-chartered banks is retrieved automatically from the call reports. State banks do not need to submit the information separately.All national banks, savings and loans, and out-of-state institutions that operate offices in Iowa must submit the information to the Superintendent quarterly. The required information is to be submitted electronically via our Public Funds web site by clicking on “Electronic Submission.” Access is provided by using the institution’s user name and password.The appropriate pledging and custodial forms can be obtained from the State Treasurer’s web site.,  Are banks required to monitor circumstances (balance levels) on a daily basis?Iowa Code Chapter 12C.22(2) and IAC 781-13.7(1) apply. Iowa Code Chapter 12C.22(2) states “The amount of the collateral required to be pledged by a bank shall at all times equal or exceed the total of the amount by which the public funds deposits in the bank exceeds the total capital of the bank.” Likewise, the rules state in 781-13.7(1) “A pledging bank shall pledge and maintain eligible collateral with the treasurer’s approved custodian by which the market value at all time equals or exceeds the amount by which the public funds deposits in the pledging bank exceed the total capital of the pledging bank.”Eligible collateral must be maintained at all times, not just at quarter end.,  Are there any exceptions for short term, large dollar deposits?A bank posed this scenario – they have the County Treasurer account, which means that approximately $35 million flows in on a semi-annual basis. Roughly half of those funds are paid out to taxing bodies on the 15th of the month following and the remainder in another 30 days. It is not practical for the bank to pledge $35-40 million given the bank’s investment portfolio and short-term nature of the deposits. The bank is trying to plan ahead with regard to discussion with the County Treasurer.The law is very specific about this situation. Iowa Code chapter 12C.22(2) states “The amount of the collateral required to be pledged by a bank shall at all times equal or exceed the total of the amount by which the public funds deposits in the bank exceeds the total capital of the bank.” Likewise, the rules state in 781-13.7(1) “A pledging bank shall pledge and maintain eligible collateral with the treasurer’s approved custodian by which the market value at all time equals or exceeds the amount by which the public funds deposits in the pledging bank exceed the total capital of the pledging bank.”There are no exceptions for short term, large dollar deposits.,  How should banks calculate their “total capital”? Is it based on their balance sheet capital or risk based capital?The formula for banks and savings and loans is in Iowa Code Chapter 12C.22(2). “Total capital of the bank means its tier one capital plus both of the following components of tier two capital: a. qualifying subordinated debt and redeemable preferred stock; b. cumulative perpetual preferred stock.”The formula for an out-of-state bank that operates a branch in Iowa is located in Iowa Code chapter 12C.22(3) a through g.You may use these forms:► Public Funds Report - National Banks► Public Funds Report - Savings & Loans► Public Funds Report - Out of State Banks with Iowa OfficesInstitutions need to develop their own internal system to track public deposits in excess of total capital on a daily basis.,  Would a bank need to pledge for deposits containing public funds from outside the state of Iowa?Iowa Code 12C applies only to Iowa public funds; therefore, the bank would not need to pledge for a deposit from an out-of-state public body to comply with Iowa Code 12C. However, the bank would need to comply with any laws which may apply to public deposits in another state.For purposes of pledging, public funds and public deposits mean the monies of Iowa or a political subdivision or instrumentality of Iowa . See Iowa Code Chapter 12C.2(e) and Iowa Administrative Rules 781-13.2 for definitions of public funds and public units for their complete definitions.Unfortunately, the call reports do not specify Iowa public deposits; therefore, the information that is retrieved from the call reports will include all public deposits, in Iowa and out-of-state.,  How is FDIC Deposit Insurance handled in the calculation of required collateral?No provisions in the law were made for FDIC insurance. Therefore, total public deposits are used. The FDIC insured amount of each depositor is NOT deducted from the total public funds.,  Which insurance companies have been approved to provide deposit guaranty bonds?Deposit guaranty bonds for public funds accounts are allowed in Section 12C.22(6)(e) of the Code of Iowa. Over the last several years market conditions have changed with this insurance product. If a bank is considering using this insurance product to secure Iowa Public Funds, please contact the Superintendent of Banking.,  Can a bank use CDRS for Iowa public fund deposits?Effective July 1, 2006, Chapters 12B and 12C of the Iowa Code were amended to permit banks to use the CDRS program for Iowa public funds, regardless of the location of the other institutions that might receive the deposits. These deposits are not considered public deposits when determining how much a bank must pledge. However, if the Treasurer has to make a sinking fund assessment, the CDRS deposits are included in determining the sinking fund assessment.,  Can an institution use bank owned time certificates of deposit as collateral for public funds deposits?Effective July 1, 2012 House File 2168 changed Iowa Code 12C 22(6-f) to allow institutions to pledge bank owned time certificates of deposit.House File 2168 effective July 1, 2012: Section 12C.22, subsection 6, Code 2011, is amended by adding the following new paragraph: NEW PARAGRAPH . f. Certificates of deposit issued by a federal deposit insurance corporation insured bank, the payment of which is fully insured by the federal deposit insurance corporation both as to principal and accrued interest, and that have been assigned a committee on uniform security identification procedures number and deposited for the account of the public funds depository bank at the depository trust company.

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Which institutions need to report their Iowa public funds and total capital? When are they required to report?Reporting to the Superintendent of Banking must be done each quarter, 10 days after the call reports are due. State-chartered banks do not need to report separately, since the information is retrieved from the call reports. However, all national banks, savings and loans, and out-of-state institutions with offices in Iowa must report to the Superintendent via the Iowa Division of Banking web site.,  How do institutions report their Iowa public funds and total capital to the Superintendent of Banking?The information needed for Iowa state-chartered banks is retrieved automatically from the call reports. State banks do not need to submit the information separately.All national banks, savings and loans, and out-of-state institutions that operate offices in Iowa must submit the information to the Superintendent quarterly. The required information is to be submitted electronically via our Public Funds web site by clicking on “Electronic Submission.” Access is provided by using the institution’s user name and password.The appropriate pledging and custodial forms can be obtained from the State Treasurer’s web site.,  Are banks required to monitor circumstances (balance levels) on a daily basis?Iowa Code Chapter 12C.22(2) and IAC 781-13.7(1) apply. Iowa Code Chapter 12C.22(2) states “The amount of the collateral required to be pledged by a bank shall at all times equal or exceed the total of the amount by which the public funds deposits in the bank exceeds the total capital of the bank.” Likewise, the rules state in 781-13.7(1) “A pledging bank shall pledge and maintain eligible collateral with the treasurer’s approved custodian by which the market value at all time equals or exceeds the amount by which the public funds deposits in the pledging bank exceed the total capital of the pledging bank.”Eligible collateral must be maintained at all times, not just at quarter end.,  Are there any exceptions for short term, large dollar deposits?A bank posed this scenario – they have the County Treasurer account, which means that approximately $35 million flows in on a semi-annual basis. Roughly half of those funds are paid out to taxing bodies on the 15th of the month following and the remainder in another 30 days. It is not practical for the bank to pledge $35-40 million given the bank’s investment portfolio and short-term nature of the deposits. The bank is trying to plan ahead with regard to discussion with the County Treasurer.The law is very specific about this situation. Iowa Code chapter 12C.22(2) states “The amount of the collateral required to be pledged by a bank shall at all times equal or exceed the total of the amount by which the public funds deposits in the bank exceeds the total capital of the bank.” Likewise, the rules state in 781-13.7(1) “A pledging bank shall pledge and maintain eligible collateral with the treasurer’s approved custodian by which the market value at all time equals or exceeds the amount by which the public funds deposits in the pledging bank exceed the total capital of the pledging bank.”There are no exceptions for short term, large dollar deposits.,  How should banks calculate their “total capital”? Is it based on their balance sheet capital or risk based capital?The formula for banks and savings and loans is in Iowa Code Chapter 12C.22(2). “Total capital of the bank means its tier one capital plus both of the following components of tier two capital: a. qualifying subordinated debt and redeemable preferred stock; b. cumulative perpetual preferred stock.”The formula for an out-of-state bank that operates a branch in Iowa is located in Iowa Code chapter 12C.22(3) a through g.You may use these forms:► Public Funds Report - National Banks► Public Funds Report - Savings & Loans► Public Funds Report - Out of State Banks with Iowa OfficesInstitutions need to develop their own internal system to track public deposits in excess of total capital on a daily basis.,  Would a bank need to pledge for deposits containing public funds from outside the state of Iowa?Iowa Code 12C applies only to Iowa public funds; therefore, the bank would not need to pledge for a deposit from an out-of-state public body to comply with Iowa Code 12C. However, the bank would need to comply with any laws which may apply to public deposits in another state.For purposes of pledging, public funds and public deposits mean the monies of Iowa or a political subdivision or instrumentality of Iowa . See Iowa Code Chapter 12C.2(e) and Iowa Administrative Rules 781-13.2 for definitions of public funds and public units for their complete definitions.Unfortunately, the call reports do not specify Iowa public deposits; therefore, the information that is retrieved from the call reports will include all public deposits, in Iowa and out-of-state.,  How is FDIC Deposit Insurance handled in the calculation of required collateral?No provisions in the law were made for FDIC insurance. Therefore, total public deposits are used. The FDIC insured amount of each depositor is NOT deducted from the total public funds.,  Which insurance companies have been approved to provide deposit guaranty bonds?Deposit guaranty bonds for public funds accounts are allowed in Section 12C.22(6)(e) of the Code of Iowa. Over the last several years market conditions have changed with this insurance product. If a bank is considering using this insurance product to secure Iowa Public Funds, please contact the Superintendent of Banking.,  Can a bank use CDRS for Iowa public fund deposits?Effective July 1, 2006, Chapters 12B and 12C of the Iowa Code were amended to permit banks to use the CDRS program for Iowa public funds, regardless of the location of the other institutions that might receive the deposits. These deposits are not considered public deposits when determining how much a bank must pledge. However, if the Treasurer has to make a sinking fund assessment, the CDRS deposits are included in determining the sinking fund assessment.,  Can an institution use bank owned time certificates of deposit as collateral for public funds deposits?Effective July 1, 2012 House File 2168 changed Iowa Code 12C 22(6-f) to allow institutions to pledge bank owned time certificates of deposit.House File 2168 effective July 1, 2012: Section 12C.22, subsection 6, Code 2011, is amended by adding the following new paragraph: NEW PARAGRAPH . f. Certificates of deposit issued by a federal deposit insurance corporation insured bank, the payment of which is fully insured by the federal deposit insurance corporation both as to principal and accrued interest, and that have been assigned a committee on uniform security identification procedures number and deposited for the account of the public funds depository bank at the depository trust company.

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