A deposit insurance scheme (DIS)  is part of a country’s financial safety net. The financial safety net protects the soundness of and confidence in the financial sector. It includes the functions of prudential regulation and supervision of financial institutions and financial market infrastructure. It also provides an effective resolution of financial institutions; is a lender of last resort that offers loans to banks that are experiencing financial difficulty; and puts forward a DIS that protects the most vulnerable customers of financial institutions by providing depositors with access to their covered deposits if a bank should fail. 

The FSR Act provides the over-arching, high-level framework for the establishment of CODI, with a dedicated DIS to be maintained and administered by CODI. CODI will use the Deposit Insurance Fund (DIF) to protect its members’ covered depositors by ensuring access to their deposits within a reasonable timeframe when a bank fails.

CODI will protect banking products where the capital amount is guaranteed and repayable at par (e.g. savings and cheque accounts). It will not protect investment products.

For example, when a bank is liquidated, CODI will use the DIF to pay out the failed bank’s covered depositors by using electronic funds transfers (EFTs) or through a payout agent bank. The proposed protection afforded to qualifying depositors will be up to a coverage limit of R100 000 per depositor per bank. 

CODI’s protection will be automatic. Depositors will not have to apply for this protection. CODI will protect deposits held by natural or non-financial persons. CODI’s protection is up to R100 000 per qualifying depositor per bank.

CODI will protect qualifying products where the nominal balance is guaranteed and repayable at par.

Qualifying accounts held by sole proprietors will be covered separately from the individuals’ personal bank accounts. The coverage limit for a sole proprietor will be R100 000 if the bank can identify the accounts the individual uses for its sole proprietor business.

Qualifying deposits in foreign currencies held by qualifying depositors are covered up to the R100 000 limit. When a bank fails, foreign currency balances will be converted to South African rand before a depositor is paid.

Membership to CODI is automatic and compulsory for all registered banks. This includes all commercial banks, local branches of foreign banks, mutual banks, and cooperative banks. Currently there are 17 commercial banks, three mutual banks, six cooperative banks and 12 local branches of foreign banks.

For a list of CODI members, click here.

Although CODI was established on 24 March 2023, it will only become fully operational by April 2024.

During the next year CODI, will work closely with National Treasury to take the deposit insurance secondary legislation through Parliament for sign-off by the President. While the FSR Act contains high-level rules for the establishment of CODI, the secondary legislation will contain detailed rules explaining the procedural and/or administrative matters relating to the operations of CODI and the DIF.

CODI is also developing technology systems to automate the collection of depositors’ information from banks to calculate the banks’ financial contributions to CODI. CODI will finalise its governance and administrative processes to collect from the banks levies for its operational costs and premiums to build the DIF. From 1 April 2024, CODI will be operationally ready to protect depositors if their bank should fail. 

Is there a need for banks to register with CODI to become members?

No. All registered banks automatically became members of CODI.

Which banks are members of CODI?

Membership is automatic and compulsory for all banks and branches registered in terms of the Banks Act 94 of 1990 (Banks Act), Mutual Banks Act 124 of 1993 (Mutual Banks Act) and the Co-Operative Banks Act 40 of 2007 (CBA). This definition includes banks operating within the borders of South Africa that are regulated and supervised by the Prudential Authority (PA) as the home or host supervisor.

Will cooperative financial institutions (CFIs) be members of CODI?

CFIs will not be members of CODI upon CODI’s establishment, but CODI will undertake work to include CFIs in the deposit insurance framework following its establishment.

Why was the maximum coverage level set at R100 000 per depositor per bank?

At a R100 000 coverage level, CODI will provide full protection for more than 95% of qualifying depositors in South Africa. CODI’s mandate is to protect the less sophisticated customers who place their money in a bank for safe-keeping.

Will CODI charge banks separately for system upgrades every few years?

No. CODI’s levy includes a reserve to budget for periodic system upgrades and maintenance.

Will a cap be applied to the financial contributions by banks to CODI to ensure that banks do not pay excessive amounts to CODI?

There is no cap on the financial contribution of a bank to CODI, but banks’ contributions will be based on the covered balance of each qualifying depositor, (i.e. up to the maximum coverage level of R100 000).

What is the difference between the premiums and the levies banks must pay to CODI? Must banks pay both premiums and levies to CODI?

Banks must pay both an annual levy and monthly premiums to CODI. CODI will use the annual levy to cover its operational costs, including staffing and systems. The premiums will be used to fund the DIF to be used to protect covered depositors.

If a bank does not have any covered deposit balances, how will it affect its financial contributions to CODI?

A bank with no covered deposit balances will still be a member of CODI and liable for the minimum annual levy. The bank will not pay the monthly premiums to CODI for as long as it has no covered deposits. The bank must still enter into a contractual agreement with CODI for the fund liquidity tier, but may not have a balance until it reports a covered deposit balance. The CEO and CFO of such a bank may have to submit a monthly declaration to CODI to confirm that the bank has no covered deposit balances. CODI may also ask the bank’s internal auditors to verify this annually.

Will CODI be independent of the SARB?

CODI will be an independent subsidiary of the SARB with its own board of directors and management team. Since CODI will be part of the broader SARB Group, it will have some governance and reporting obligations to the SARB, but its board will be responsible for overseeing CODI’s operations.

Why could CODI not use the banks’ returns submitted to the PA?

Banks currently submit aggregated balances on balance sheet, income statement and risk-related items to the PA. CODI requires granular depositor information to enable it to fulfil its mandated function of protecting the covered depositors of a bank in resolution.

CODI requires banks to submit depositors’ personal information in their quarterly deposit insurance submissions. Has CODI considered the compliance requirements of the Protectional for Personal Information Act 4 of 2013 (POPIA)?

Yes. CODI is working with the SARB’s POPIA team to ensure that it complies with the requirements of POPIA.

Will banks be required to provide depositor information in a single customer view format?

Yes. Where a bank is initially unable to report depositor information to CODI in a single customer view (SCV) format, a bank can apply for condonation from this requirement. Upon assessing the bank’s request, CODI may grant the bank condonation to give the bank more time to comply to this requirement.

Will banks report month-end or average balances to CODI?

A deposit insurer needs updated balances as at a point in time. The monthly deposit insurance submissions will be based on month-end figures. When CODI requests ad hoc submissions, it will specify the date on which the bank must base the submission.

How frequently will banks do deposit insurance submissions to CODI?

Banks will submit their qualifying and covered deposit balances to CODI on a monthly basis. On a quarterly basis, they will submit these balances with the SCV calculations to CODI.

When a local branch of a foreign bank is a member of a foreign deposit insurance scheme, will it still be a member of CODI?

The FSR Act does not allow for the exemption of any member banks from being a member of CODI. Future amendments to the FSR Act may be considered to allow local branches of foreign banks that are already members of a foreign deposit insurance scheme to apply for exemption. CODI and the foreign deposit insurer will then agree which DIS the branch will be a member of.

What will CODI do with unclaimed amounts it cannot pay out?

Any unclaimed deposits will remain in the estate of the failed bank and will be managed by the liquidator in terms of the creditor hierarchy.