Securing Government Deposits In Federal Entity Accounts
This chapter prescribes federal entity requirements for securing public money on deposit at depositaries.
Section 9010—Scope and Applicability
When a federal entity places funds on deposit with a financial institution, the financial institution must pledge collateral under conditions prescribed in this chapter. The pledging of collateral by a financial institution is necessary to protect the federal government against risk of loss. State, local, and municipal deposits are not covered under this chapter.
See 12 U.S.C. 90, 265, 266, and 1789a; 31 U.S.C. 321 and 3303; and 31 CFR 202 and 380.
Section 9020—Terms and Definitions
For terms and definitions related to this chapter, please view the TFM Glossary.
Section 9025—Responsibilities for Public Money
The Department of the Treasury’s (Treasury) Bureau of the Fiscal Service (Fiscal Service) promulgates rules and provides guidance for the security of public money on deposit in depositaries. The rules outlining broad policy objectives with securing such funds are included in 31 CFR 202 and related collateral guidance in 31 CFR 380. The Treasury Financial Manual provides more detailed policy guidance and detailed procedures that federal entities, depositaries, and Federal Reserve Banks (FRB) must follow to ensure the funds are secured. Each federal entity must remain informed of and compliant with the latest collateral regulations, rules, and procedures.
Fiscal Service determines the types of acceptable collateral depositaries can use to secure deposits of public money. Fiscal Service also determines appropriate margins on pledged collateral.
The following subsections outline the distribution of responsibilities for securing deposits of public money.
Each federal entity must:
- Establish a Treasury Collateral Management and Monitoring (TCMM) account and V account by completing the TCMM Agency Access Authorization Form.
- Provide the TCMM Operations Team with a timely annual update of contact information.
- Notify the TCMM Operations Team immediately when there are changes to authorized individuals. See the Treasury Collateral Management and Monitoring website to obtain the form to update contact information.
- Provide timely address changes to the TCMM Operations Team.
- Notify Fiscal Service, in writing, when canceling a V account. The federal entity must state that it no longer has collateral holdings and no longer needs the V account.
- Develop and maintain internal operating procedures to ensure the security of public money. Fiscal Service may request a copy of federal entity procedures.
- Ensure that TCMM has the most accurate and up-to-date amount on deposit to be collateralized. This allows the TCMM Operations Team to maintain sufficient collateral in excess of the recognized deposit insurance limit (generally $250,000). See 12 CFR 330 (Deposit Insurance Coverage).
- Monitor federal entity collateral records by reviewing the monthly FRB Security Account Holdings Report and the Collateral Monitoring Recap Report. The Security Account Holding Report lists all securities pledged to a federal entity. The Collateral Monitoring Recap Report provides federal entities and financial institutions with a recap of security collateral values and the amount to be collateralized for their V accounts throughout the month. Both reports are available in the TCMM application.
All FRBs must secure pledged collateral to protect public funds.
9025.30—TCMM Operations Team
The TCMM Operations Team must:
- Ensure that pledged collateral is eligible and sufficient to secure deposits of public money.
- Maintain and distribute FS Form 5902: Collateral Security Resolution (Revised May 2015); and FS Form 5903: Collateral Pledge and Security Agreement (Revised May 2015). See the Treasury Collateral Management and Monitoring website to obtain these forms.
- Maintain a current list of collateral contacts.
- Make available the FRB Security Account Holdings Report and the Collateral Monitoring Recap Report to federal entities on a monthly basis through TCMM.
- Make available the Collateral Monitoring Recap Report to depositaries on a monthly basis through TCMM.
- Open collateral accounts in National Book Entry System (NBES), Collateral Management System (CMS), and TCMM.
- Value collateral.
- Complete FS Form 5902 and FS Form 5903 and submit these forms to the TCMM Operations Team to establish collateral security accounts.
- Pledge sufficient eligible collateral security as required by the Secretary of the Treasury.
- Provide federal entities and FRBs with requested information.
- Advise federal entities when the depositary is not able or willing to pledge collateral.
Fiscal Service must:
- Assign and maintain V account numbers and provide federal entity information to the FRB so that the FRB may establish accounts.
- Establish the collateral policy.
- Establish and maintain lists of acceptable collateral and assigned margins.
- Periodically update the criteria and guidance for acceptable collateral and applicable margins. See the TreasuryDirect website.
Section 9030—Selection of a Depositary
A federal entity with statutory authority to hold public money outside of Treasury’s cash account must deposit funds in a financial institution meeting the requirements of 31 CFR 202. Federal entities are encouraged, but not required, to use minority financial institutions as depositaries whenever these institutions can provide required banking services without an appreciable increase in cost or risk to the government. Treasury’s Minority Bank Deposit Program (MBDP) is a voluntary program to encourage federal entities, state and local governments, and the private sector to use participants as depositaries and financial agents. Fiscal Service annually certifies qualified minority institutions and maintains a roster of MBDP participants (see the Minority Bank Deposit Program website).
Section 9035—Establishing a Federal Entity Collateral Account
To acquire a V account, federal entities must fill out and submit the TCMM Agency Access Authorization Form. Each federal entity must use its V account number to establish an account at an authorized depositary. Also, federal entities use their V accounts in TCMM for managing their collateral requirements. Fiscal Service assigns federal entity account numbers.
Section 9040—Securing Federal Entity Accounts
All public money deposited in a depositary must always be fully secured. The current federal deposit insurance limit per insured account is $250,000. Public money is considered sufficiently secured if:
- The total amount of a federal entity's deposits in a single depositary is less than the recognized deposit insurance limit, or
- The depositary pledges eligible collateral before a federal entity deposit exceeds the recognized deposit insurance limit.
9040.10—Federal Deposit Insurance Corporation (FDIC) Regulations
Under FDIC regulations:
- Federal entity deposit accounts maintained at different branches or offices of the same insured depositary are not separately insured.
- Each “official custodian” of public money in a depositary is separately insured for $250,000 in the aggregate for “time and savings deposits” and $250,000 in the aggregate for all “demand deposits.” See 12 CFR 330.15(a). The FDIC regulations do not limit the number of official custodians a federal entity may have. Therefore, if a federal entity has three official custodians, each with a “time and savings deposit” account and “demand deposit” account, each account is insured for $250,000.
9040.20—Securing Deposits With Collateral
When a federal entity's deposits of public money exceed the recognized deposit insurance limit (generally $250,000), the federal entity must request that the depositary pledge eligible collateral to secure the uninsured amount. The depositary must pledge collateral with an FRB or an authorized third-party custodian approved by the FRB. If a third-party custodian is used, the depositary must notify the FRB by a trust receipt.
The TCMM Operations Team must ensure the depositary pledges collateral according to the list of “Acceptable Collateral for Pledging to Federal Agencies” under 31 CFR 202 and 380. See the TreasuryDirect website.
This collateral requirement applies to total federal entity deposits at a depositary that exceed the applicable insurance limit, regardless of how many accounts and whether the deposits are spread among several branches.
Section 9045—Pledging Collateral
When a federal entity deposits public money in a depositary account for the first time and the balance exceeds the deposit insurance limit, the federal entity must request that the depositary pledge collateral to the FRB using the federal entity’s V account. This designated account number must be used on all collateral transactions.
When a federal entity anticipates its deposits will exceed the insurance limit, it must provide the TCMM Operations Team with information about the pledging depositary, an authorized collateral contact, and the amount to be collateralized. The federal entity must await notification from the TCMM Operations team that an account relationship has been set up in NBES and CMS for the federal entity, and that federal entity access to TCMM has been established. After access to TCMM has been established, the depositary must pledge sufficient collateral, as shown in TCMM, to cover a federal entity's deposits at the depositary.
9045.20—Requesting Additional Collateral
Using TCMM, the TCMM Operations Team monitors collateral balances to ensure that sufficient collateral has been pledged to cover a federal entity's deposits at the depositary. When the federal entity requires additional collateral to secure these deposits, the federal entity requests the depositary to pledge additional collateral. The federal entity must review the FRB Security Account Holdings Report and the Collateral Monitoring Recap Report available in TCMM to ensure that the amount to be collateralized is adequate. The federal entity must ensure that TCMM has the most accurate amount to be collateralized so that TCMM Operations Team can monitor the collateral pledged for sufficient value. The TCMM Operations Team will contact the depositary to request additional collateral, if necessary.
9045.30—Information Required by Fiscal Service
Initially, federal entities must provide the TCMM Operations Team with a completed TCMM Agency Access Authorization Form and must annually recertify federal entity TCMM users and contacts.
Section 9050—Releasing Collateral
9050.10—TCMM Operations Team Responsibilities
The TCMM Operations Team approves all releases of collateral. The TCMM Operations Team may release collateral as long as such action does not cause an account deficiency. If a depositary requests the release of collateral that would cause a deficiency, the TCMM Operations Team instructs the federal entity to inform the depositary of this potential deficiency situation and requests the depositary to pledge replacement collateral. If there are questions regarding the amount to be collateralized, the TCMM Operations Team works with the depositary to contact the federal entity to determine the exact amount to be collateralized. Updates for the amount to be collateralized are not processed without proper authorization from the federal entity.
In the case of a failed or insolvent depositary, only Fiscal Service has the authority to instruct the TCMM Operations Team to release collateral (see subsection 9060.20).
9050.20—Federal Entity Responsibilities
The TCMM Operations Team contacts federal entities if it is determined that a deficiency would result from a collateral release. Federal entities must confirm that the amount to be collateralized is sufficient. The federal entity may reduce the amount to be collateralized if applicable.
If a federal entity wants to close a V account, it must notify the TCMM Operations Team by telephone or in writing that the deposit balance is zero and collateral is no longer needed. The federal entity also must notify Fiscal Service in writing that the federal entity no longer needs the V account.
Only after a federal entity sets the amount to be collateralized to zero within TCMM, which eliminates the need for collateral, will the TCMM Operations Team release collateral.
When the TCMM Operations Team releases pledged collateral, a federal entity must:
- Update internal record keeping.
- Verify that all information regarding the release is correct upon receipt of the Collateral Monitoring Recap Report.
- Retain this report as part of its collateral records.
Section 9055—Monitoring Collateral Levels
The TCMM Operations Team ensures that collateral values equal or exceed the amount to be collateralized. Federal entities must maintain adequate records to ensure that the amount to be collateralized on federal entity reports accurately reflects the amount on deposit over the applicable deposit insurance coverage. Federal entities must document that deposits are always protected and must ensure that the TCMM has an accurate amount to be collateralized. TCMM provides reports and real-time inquiries to assist federal entity collateral management and record keeping.
9055.10—Verifying Collateral Amounts
Federal entities must ensure that TCMM is reporting the most accurate and up-to-date amount on deposit to be collateralized. They must maintain individual subsidiary records that can independently verify each TCMM amount to be collateralized balance.
9055.20—Monthly Reconciliation Statements
On a monthly basis, the FRB Security Account Holdings Report and the Collateral Monitoring Recap Report are available in TCMM for each federal entity. Each federal entity must review these reports to ensure that the holdings are sufficient, and most importantly, that the collateralized balance is shown correctly and reflects the account balance (in excess of applicable insurance) on deposit at the depositary. The federal entity must notify the TCMM Operations Team immediately if there is a discrepancy in the amount to be collateralized.
Section 9060—Mergers and Insolvencies
It is important that federal entity and TCMM Operations Team collateral records correctly reflect the outcome of depositary mergers. This ensures that collateral deficiencies do not develop. When a federal entity maintains accounts with two depositaries, each account is separately insured by recognized deposit insurance (generally $250,000). If two depositaries serving the same federal entity merge, the surviving depositary may need to pledge additional collateral to replace the insurance coverage lost because of the merger.
If a federal entity maintains public funds in an account at a depositary that becomes insolvent, the federal entity must immediately contact Fiscal Service (see Contacts). Fiscal Service will guide federal entities in the disposition of the collateral on deposit with the depositary. The proceeds of collateral on deposit with a depositary will be applied to satisfy any claim of the United States against the depositary, not just the amount placed on deposit by the federal entity.
Direct questions regarding this chapter to:
Department of the Treasury
Bureau of the Fiscal Service
Revenue Collections Management
3201 Pennsy Drive, Building E
Landover, MD 20785
Contact the TCMM Treasury Support Center at:
TCMM Operations Team
Federal Reserve Bank of St. Louis
1421 Dr. Martin Luther King Drive
St. Louis, MO 63016-3716
Telephone: 888-568-7343, option 2
Email: TCMM TSC@stls.frb.org
For information describing acceptable collateral and its valuation, see the TreasuryDirect website.
For information on collateral policy, see the Treasury Collateral Management and Monitoring website.
Summary of Updates in this Release
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