Qualified Public Depositories
Two of the major characteristics of banks and savings associations are that they accept funds for deposit and use those funds to make loans or other investments. Many banks and savings associations are interested in increasing the amount of funds on deposit at their institution and the public funds market is a key area in which they can do so. In order to accept Florida public funds for deposit, a bank or savings association must have status as a qualified public depository ("QPD"). A QPD is defined as a bank or savings association that has:
- A branch office(s) authorized to receive deposits in Florida, has
- FDIC deposit insurance,
- Meets the requirements of Chapter 280, F.S., and
- Been designated by this office as a QPD.
QPD status is achieved by filing the required application materials with BCM and meeting certain financial condition standards. Please note that the statutory definition of QPD does not include credit unions and therefore credit unions are not eligible to serve as a QPD in Florida.
Please view the topics below for further information:
Banks and savings associations that are interested in applying for status as a qualified public depository (“QPD”) can access the QPD Applications page for the required application documents and related information.
If you prefer you may contact Donna Earnest of our staff at (850) 413-3381 or Donna.Earnest@MyFloridaCFO.com to request that an application package be sent by email. The application materials must be filed in original form with our office.
Please note that an applicant must have an average financial condition ranking of 20 or more from two nationally recognized bank rating services for approval as a QPD. Our office uses IDC Financial Publishing, Inc. and FIS FedFis, LLC for such rankings. Ms. Earnest of our staff can inform you if your institution meets or exceeds this standard.
In addition, please note the following application issues:
- QPD applicants must have their principal place of business in Florida or have a branch office in Florida that's authorized to accept deposits.
- An applicant's board of directors must adopt several key resolutions as part of the application process. These resolutions involve the required contingent liability and collateral control agreements, an optional Federal Home Loan Bank letters of credit agreement, and the identification of an applicant’s authorized signers.
- All QPDs share contingent liability in Florida's public deposits program in the event of a QPD failure. Florida has an outstanding record in the administration of its public deposits program and has never made an assessment on other QPDs.
- Florida's public deposits program includes minimum required collateral ("MRC") of $100,000 even if a QPD holds no Florida public deposits.
QPD Laws and Regulations
It’s important for qualified public depositories (“QPDs”) and QPD applicants to be familiar with and understand Florida’s law and regulations governing the public deposits program. The law and regulations detail compliance responsibilities, establishes the type of assets that are eligible as collateral, and explains the collateral pledge levels that are available in the program. The "Florida Security for Public Deposits Act", Chapter 280, Florida Statutes (“F.S.”), is the law that governs Florida's public deposits program. Rule Chapter 69C-2, Florida Administrative Code ("F.A.C."), contains the rules and forms for the program.
Please click on the topics below to learn more about QPD law and regulations:
QPD Collateral Requirements
Florida’s public deposits program has four standard collateral pledging levels of 25%, 50%, 110%, and 150%. The program's administrative rules provide the details on how a QPD's collateral pledge level is to be determined and involves consideration of a QPD's average financial condition ranking from two nationally recognized financial rating services as well as consideration of financial ratios, trends, and other pertinent information. QPDs with higher rankings and stronger financial condition will be eligible for the 50% and 25% collateral pledge levels which is an advantage that helps in the areas of liquidity and asset management.
BCM notifies all QPDs of their average financial condition ranking each calendar quarter and also notifies QPDs of any collateral pledge level changes as such decisions are made.
QPDs whose average ranking falls to the lowest range of 0-15 must withdraw from the public deposits program or agree to a limit on the amount of public deposits it will hold and pledge or deposit collateral equal to 150% of such limit.
Please see the administrative rules for additional information. A QPD may use cash, U.S. Treasury securities, U.S. agency securities, investment grade municipal and corporate bonds, as well as Federal Home Loan Bank letters of credit as collateral in Florida's public deposits program as outlined in Section 280.13, F.S.
QPDs are required to file the following reports with BCM:
Qualified Public Depository Monthly Report
- This report lists the average balance of public deposits held during the month, the applicable amount of FDIC insurance, the amount of required collateral, equity capital and total assets data, and details on the collateral protecting the public deposits.
- The report is required to be submitted within 15 days after the end of each month, or by the next business day if the 15th falls on a holiday or weekend.
Qualified Public Depository Annual Report
- This report includes information on a QPD’s compliance with program requirements, including a list of all Florida public depositors with funds on deposit at the QPD.
- The report is as of September 30th and must be filed on or before November 30th each year.
Other documents, reports, records
- At times our office may require additional documents, reports, records or other information necessary to determine a QPD’s compliance with Chapter 280, Florida Statutes.
QPD Compliance Responsibilities
While QPDs should be familiar with all provisions of Chapter 280, F.S. and Rule Chapter 69C-2, F.A.C., Section 280.16, F.S. details some key compliance responsibilities for QPDs. A QPD’s primary compliance responsibilities are:
- Identify Florida public deposit accounts in the QPD’s records and information systems.
- Execute and return to Florida public depositors the Public Deposit Identification and Acknowledgment form that is used by such depositors to identify their public deposit accounts to a QPD.
- Complete and submit the QPD Monthly Report by the 15th of each month.
- Complete and summit the QPD Annual Report by November 30th each year.
- Provide each Florida public depositor with the required account confirmation data by October 30th each year.
- Participate in the Financial Literacy Program for Individuals with Developmental Disabilities as required under s. 17.68, Florida Statutes.
BCM has an External Collateral Administration Program ("ECAP") that allows users to log into our system with useful capabilities such as submitting monthly reports, reviewing currently pledged or deposited collateral, updating contact persons, and adding additional external users.
ECAP is a secure website so you can have confidence that submitting your monthly reports is safe.
Please note, ECAP has the following limitations: a QPD may not initiate collateral deposits or releases through ECAP and QPD annual reports may not be filed through ECAP. These limitations are due to the fact that such filings results in errors when a collateral item does not yet exist in our system or when a public depositor record hasn’t been established in our system.