FRB Atlanta Borrower-in-Custody (BIC) Program

Last Updated: 09.08.2026

Please see the Pledging Loans page for additional information regarding the BIC Program.
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Borrower-In-Custody (BIC) Program
The BIC Program allows depository institutions to pledge their loans to Reserve Banks while maintaining possession of the loan documentation either on their own premises or on the premises of an approved third-party custodian by establishing a BIC arrangement. 

Generally, depository institutions eligible for Primary Credit qualify for BIC arrangements. A depository institution not eligible for Primary Credit may qualify for a BIC arrangement at the discretion of its Reserve Bank; however, additional criteria and program requirements may apply. If your institution does not qualify for Primary Credit, but you wish to pledge loan collateral to FRB Atlanta, please contact us at collateral@atl.frb.org.

All pledged loans must comply with the loan collateral terms and conditions, as amended from time to time, in (a) the Reserve Banks’ Operating Circular No. 10 "Lending" (OC-10), (b) the Acceptance Criteria for Loans section of the Collateral Eligibility – Securities and Loans page, and (c) the Reserve Banks’ BIC program requirements detailed below (collectively, the “Requirements”). 

Depository institutions pledging loans as collateral must submit their initial Collateral Schedule(s) within 12 months after the date of the approval letter from their local Reserve Bank and, at a minimum, monthly thereafter. This Collateral Schedule must include specific data elements for each pledged loan and follow the format and file specifications detailed in the Loan Collateral Schedule Submission Process section on the Pledging Loans page of this website.  Reserve Banks will work with depository institutions to confirm that Collateral Schedules meet file specifications and are in an acceptable format.

The format of the Collateral Schedule will depend on whether your institution meets the in-scope definition for the new ALD (automated loan deposit) requirements:

• If your institution is defined as in-scope, you will need to submit a Collateral Schedule via a pipe-delimited format file per the file format specifications noted. In-scope institutions will need to report if a loan is a participation or syndication loan.
• If your institution does not meet the definition of an in-scope institution, you will need to submit an out-of-scope Collateral Schedule via an Excel file template.
• Additional information on pledging requirements can be found on the Pledging Loans page.

Withdrawal Process
If you would like to withdraw from the BIC program or withdraw entire loan categories, complete the following document and submit to collateral@atl.frb.org.

Withdrawal Form - This document should be submitted when withdrawing an entire pledge portfolio. This form must be signed and emailed by an authorized official of your institution, as designated by the appropriate individual(s) as designated on Appendix 3 or Appendix 4 Form of OC-10 Official Authorization List.

Additional Information
Zix Instruction Guide: This document is an instructional guide for emailing collateral schedules, required forms, and collateral-related questions to the Federal Reserve through ZixCorp, an approved secured method of transmission.

Discount Window Direct (DWD), a self-service application accessed through FedLine®, enables users to deposit, revalue, and withdraw BIC pledges via DWD. If your institution is interested in using DWD to streamline Discount Window loan requests and to maintain BIC collateral, setup instructions can be found on the DWD page.