Improvements to the Borrower in Custody Program

August 06, 2026

Effective September 8, 2026, the Federal Reserve is updating aspects of the BIC program as part of ongoing discount window modernization. Through the BIC program, eligible institutions may pledge a wide variety of loan types to maximize liquidity while maintaining possession of the collateral. 

Upcoming changes include: 

1) Simplified forms
New application, modification, and certification forms will be used across Reserve Banks. These forms are described as “easy to use” by institutions that participated in a pilot of the updated program.

2) Faster enrollment
Most institutions will no longer be required to have pre-enrollment inspections. In many cases, application documentation will be streamlined.

3) Automated pledged loan lists
Collateral Schedules can now be uploaded online via Discount Window Direct.

4) Modified maintenance
Ongoing BIC maintenance will be updated. Instructions for certifying ongoing program compliance will be simplified. Institutions will no longer need to report when the aggregate current outstanding balance of pledged loan collateral has declined by more than 10 percent.

5) Focused inspections
Periodic inspections will be restructured to focus on three main items: 1) validation of data quality, 2) satisfaction of acceptance criteria for pledged loans, and 3) confirmation of the institution’s internal controls to ensure the pledged loans are identified as pledged to the Reserve Bank and subject to Reserve Bank control. Required supporting documentation will be narrowed.

6) Centralized resources  
BIC requirements and forms will be posted in one place on the discount window website, making it easier to find the information institutions need.  

Questions?
More detailed information about these changes will be posted on the discount window website in September. Local Reserve Bank discount window teams may reach out to current BIC program institutions in the near term and will be available to answer questions.