Reference: FIL-25-2026
Official publication: Read the full FIL-25-2026 on the agency website
The annual Summary of Deposits (SOD) survey remains a cornerstone of the Federal Deposit Insurance Corporation’s (FDIC) data collection efforts, providing the granular branch-level data necessary for comprehensive market share analysis and the evaluation of bank merger applications. For the reporting period ending June 30, 2026, the FDIC has issued updated instructions to ensure that all insured depository institutions accurately reflect their deposit footprints. This data is not only used by regulators to monitor the health of the banking system but is also a primary source of information for the public and the financial services industry regarding the competitive landscape of local banking markets. Proper preparation for this filing requires a coordinated effort between accounting, IT, and compliance departments to ensure that every deposit account is mapped correctly to its respective physical or digital office.
Executive Summary
- Survey Scope: The Summary of Deposits (SOD) is the annual survey of branch office deposits as of June 30, 2026, for all FDIC-insured institutions, including those with only a main office.
- Exclusive Filing Channel: All institutions must submit their survey data electronically through the Central Data Repository (CDR) portal; manual or paper submissions are not permitted.
- Reporting Accuracy: Accurate reporting is critical because the data influences Community Reinvestment Act (CRA) evaluations, antitrust reviews in merger and acquisition scenarios, and the public’s understanding of local market competition.
- Branch-Level Mapping: Institutions must verify that their branch structure in the FDIC’s database is current before submitting deposit totals, ensuring that new branches are added and closed branches are properly terminated.
- Data Consistency: Total deposit amounts reported in the SOD must reconcile with the total deposits reported in the Consolidated Reports of Condition and Income (Call Report) for the same period.
What the Regulator Issued
The Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution Letter (FIL) providing official notice and detailed instructions for the 2026 Summary of Deposits survey. The release specifies the technical requirements for accessing the Central Data Repository and the procedural steps for data validation. The full text of the announcement and the associated reporting instructions can be accessed through the official FDIC portal at https://www.fdic.gov/news/financial-institution-letters/2026/summary-deposits-survey-and-filing-june-30-2026. The guidance emphasizes that the data reported must represent the totals as of the close of business on June 30, 2026.
Who Is Impacted
The Summary of Deposits filing is mandatory for all FDIC-insured depository institutions. This includes commercial banks, savings associations, and state-chartered institutions. While the survey is most complex for institutions with extensive branch networks, single-office institutions are also required to file to confirm their total deposit holdings at their primary location. Within these institutions, the filing process typically impacts the Chief Financial Officer, the Compliance Officer, and the IT personnel responsible for data extraction and submission. Furthermore, third-party service providers who assist banks with regulatory reporting must ensure their software is updated to the latest CDR specifications for the 2026 cycle.
Key Dates and Deadlines
- Reporting Date: Data must reflect deposit balances as of the close of business on June 30, 2026.
- Filing Deadline: While the FDIC generally allows approximately 30 days for submission, the specific deadline for the 2026 survey is typically July 31, 2026. Institutions should verify the final date within the CDR system.
- Structure Updates: Any changes to the institution’s branch structure (names, addresses, or office types) should be completed in the FDIC’s structure system well in advance of the June 30 reporting date.
Practical Action Checklist
- Verify CDR Access: Ensure that all personnel responsible for the filing have active accounts in the Central Data Repository (CDR) and that their passwords have not expired prior to the June 30 reporting date.
- Reconcile Branch Structures: Cross-reference the institution’s internal branch list with the FDIC’s list of branches to identify any discrepancies in addresses or service types that need to be corrected before the filing begins.
- Review Deposit Allocation Logic: Verify the internal methodology used to assign deposit accounts to specific branches, particularly for deposits originated through online channels or mobile banking units that may not be tied to a traditional physical office.
- Coordinate with IT for Data Extraction: Schedule the extraction of deposit data for the close of business on June 30 to ensure that the figures are captured accurately before the start of the next business cycle.
- Execute Reconciliation with Call Report: Compare the aggregate SOD deposit totals with the figures reported on Schedule RC-O of the June 30 Call Report; any significant variances must be documented and explained.
- Identify Closed or Sold Branches: Confirm that any branches closed or sold during the preceding twelve months have been properly updated in the FDIC’s system to prevent erroneous reporting for those locations.
- Assess Brokered Deposit Reporting: Ensure that brokered deposits are assigned to the correct office in accordance with the FDIC’s Summary of Deposits Instructions, which generally require assigning them to the main office unless otherwise specified.
- Test Validation Rules: Utilize the CDR’s built-in validation checks to identify and resolve any mathematical or logical errors before the final attestation and submission.
- Obtain Executive Sign-off: Establish a formal internal review process where the final SOD report is reviewed and approved by an executive officer to ensure accuracy and accountability.
- Monitor Submission Status: After clicking “submit” in the CDR, monitor the system to confirm that the filing has been accepted and that no further “edit checks” or corrections are required by the regulator.
Open Questions / Watch Items
One area of ongoing scrutiny is the treatment of “virtual” or “digital-only” branches. As more institutions move away from physical footprints, the FDIC continues to evaluate how these deposits should be reported to ensure market share data remains relevant. Institutions should monitor for any supplemental guidance regarding the reporting of deposits at non-traditional locations. Additionally, the industry should watch for potential changes in the definition of “deposit” for SOD purposes, particularly if new types of fintech-driven accounts are introduced into the regulatory framework. Finally, the accuracy of the SOD data remains a key factor in the FDIC’s assessment of competitive effects during merger reviews, making the precision of branch-level reporting more important than ever in a consolidating market.
My Law Tampa publishes this regulatory update to assist financial institutions in maintaining compliance with federal reporting requirements. We focus on providing detailed, actionable insights into the evolving landscape of banking regulation and compliance management.
This memorandum is provided for informational purposes only and does not constitute legal advice. The distribution of this information does not create an attorney-client relationship between the reader and My Law Tampa. Organizations should consult with qualified legal counsel regarding the specific application of these regulations to their operations.
Source Materials
- Official publication: FIL-25-2026
- Regulator archive: FDIC memo archive
- Memo library: browse the full regulatory memo archive
- Related memo: FDIC Proposes Rigorous BSA and Sanctions Standards for Permitted Payment Stablecoin Issuers
- Related memo: Modernizing the CAMELS Framework: Analyzing the FDIC’s Proposed Revisions to the Uniform Financial Institutions Rating System
- Related memo: FDIC Compliance: Analysis of the 2026 Updated Q&A on Official Signs and Advertising Requirements
