On May 1, 2017, the FDIC released an update to its guidance on
the de novo banking – "Applying for Deposit Insurance
– A Handbook for Organizers of De Novo Institutions."
The updated guidance purports to provide organizers with a
"clear and transparent explanation of the path to obtaining
deposit insurance." This may be the FDIC's response to the
2014 joint letter of the American Association of Bank Directors
(AABD) and the Independent Community Bankers of America (ICBA) in
which the AABD and the ICBA recommended that the FDIC issue a new
Financial Institution Letter (FIL) to "to help dispel
misconceptions and reaffirm the FDIC's support for the
formation of de novo banks." These misconceptions relate to
the uncertainty in the application process, the second-guessing of
business plans for a de novo bank, capital requirements,
examination schedules and the degree of regulatory oversight during
the first seven years. The FDIC appears to be on a
"get-out-the-message"
