FDIC insurance is subject to FDIC rules, including for pass-through coverage, which require certain conditions to be satisfied for deposit insurance coverage to apply.

FDIC Rule 370 requires large depository institutions have the ability to accurately calculate FDIC insurance coverage for all depositors in the event of failure. In most instances Wells Fargo has the information within our systems of record to meet this requirement. However, we do not always have information for the insured parties on third party accounts where FDIC insurance passes through our direct customer to the customer of our customer (funds owner). Insured deposits for third party accounts cannot be released to customers until Wells Fargo receives the data and completes insurance calculations. For this reason the FDIC offers alternative recordkeeping to allow third party account holders to submit this information as needed at the time of failure.

Alternative recordkeeping allows for the electronic submission of third party funds owner information in order to expedite the insurance determination. Files are only submitted in the event of failure and requirements are outlined in the FDIC Deposit Brokers Processing Guide. All third party account holders storing funds owner data, in lieu of the bank doing so, are eligible to submit a file regardless of whether they are a deposit broker or not. Files may also be submitted by mail to the FDIC directly; however, this may result in a lengthier deposit insurance determination due to the manual nature of the processing.

Well Fargo options for alternative recordkeeping

Wells Fargo has established two transmission options for the submission of alternative recordkeeping files in the unlikely event we are placed into receivership by the FDIC.

Automated FDIC transmission

Automated FDIC transmission setups accommodate our customers who desire the ability to generate and submit an alternative recordkeeping file directly to Wells Fargo from their system of record in real time. Our Implementations team works directly with automated transmission customers to establish a digitally secure connection and facilitate testing of the file submission to ensure proper formatting. The benefit of this service is to expedite insurance calculations to avoid FDIC delays in releasing insured funds to customers. 

If you are interested in the automated transmission option please contact your banker and refer to the file formatting specifications in the section below. 

Ad-hoc FDIC transmission

The ad-hoc transmission process was established for third party pass-through account holders or servicers that prefer not to build a direct connection from their system of record. If Wells Fargo were to fail, this option allows our customers to obtain credentials to use our secure transmission service to submit funds owner data within 24 hours of our failure.  We have made this process as simple as possible to avoid any undue delays in processing your submission. 

The below instructions would only need to be followed in the event of a bank failure. IMPORTANT: We encourage you to test this functionality by using the same instructions below. For more information on submitting a test file please contact your banker.

1.    Request access

Send an email to fdicalternativerecordkeeping@wellsfargo.com requesting credentials to submit an ad-hoc alternative recordkeeping file. Include the following in your request:

  • Subject line of email must read “ARK Credentials Request”
  • Customer name
  • State, country, time zone
  • Customer contact name, email, and phone number
  • Customer alternate contact name, email, and phone number (if applicable)

You will receive an email with a link to our financial transmission services mailbox along with credentials that will allow you to submit your file(s).

2.    Create and submit your alternative record keeping file

The FDIC requires an ASCII flat, delimited file. If your company chooses to create the file manually, one option is to load the information in Excel and simply save as .txt tab delimited. Wells Fargo requires you to save the file using the below format:

  • customername_YYYYMMDD_v<sequencenumber>_data.txt (customer name should be all lower case and sequence starts with 1 and ascends with each additional file - e.g. acmecompany_20211201_v1_data.txt)

The file will consist of 29 columns with no header records. The first 19 columns follow the FDIC broker submission format followed by 10 addendum fields.

Please note:

  • FDIC guidance indicates the “customer account number” field is optional. This field allows you to assign a unique identifier to each account in the file for easier reconciliation and it is required by Wells Fargo. 
  • If account holder owns any balances in the account for which the file is being submitted, account holder must include their own entity information in the alternative recordkeeping file to identify those balances.

3.    Create and submit your control file

Wells Fargo requires a separate control file be submitted with each alternative recordkeeping file. Formatting requirements for the control file are as follows:

  • Column A = Record count in file
  • Column B = Customer contact name
  • Column C = Customer contact email
  • Column D = Customer contact phone number

Do not use header records.

The control file should be saved as an ASCII flat, delimited file as follows:

customername_YYYYMMDD_ v<sequencenumber>_control.txt (customer name should be all lower case and sequence starts with 1 and ascends with each additional file – e.g. acmecompany_20211201_v1_control.txt)

4.    Receive confirmation

When your file is received, Wells Fargo will review it and email the company contact designated in your control file to inform them if there are any errors in the file that prevent it from processing properly. Otherwise, you will receive a deposit resolution file and control file after your customer accounts are dispositioned. The deposit resolution file will provide the result of the insurance calculation including:

  • Accounts with balances fully covered by deposit insurance
  • Accounts with uninsured balances that have been seized by the FDIC

The deposit resolution file will be a tab delimited file without any leading or trailing spacing or zeros between the data fields as follows:

  • Column A = Wells Fargo account number if non-DO Broker submission or Broker Number if it is a DO Broker submission 
  • Column B = Customer defined account number 
  • Column C = CUSIP (if DO Broker, otherwise blank)
  • Column D = Debit amount (This represents the uninsured amount. An amount of 0.00 indicates there is nothing to debit and all funds for account identified in column B are fully insured) 
  • Column E = Credit amount (amount > 0.00 indicates a credit to previously withheld funds)

The deposit resolution file will be saved as follows:

  • customername_debits_releaseholds_YYYYMMDD_<cycle_num>_data.txt
  • There will be no header records in this file
  • Cycle number is an internal sequence number Wells Fargo uses each time a file is generated

A control file will be generated along with the above deposit resolution file. 

  • Column A = Customer Name 
  • Column B = Date Timestamp when the file was generated
  • Column C = Total count of Records in deposit resolution file
  • Column D = Static value of FDIC Rule 370 – Wells Fargo
  • Column E = Data file name
  • Column F = Blank for future use

The deposit resolution control file will be formatted saved as follows:

  • customername_debits_releaseholds_YYYYMMDD_<cycle_num>_control.txt