A Primer: The Federal Reserve's E-Apps Filing System
Appeared in the Summer 2013 edition of The Bankers' Statement
The Federal Reserve System recently streamlined the registration process for the Electronic Applications (E-Apps) system it initially launched in early 2010. E-Apps is a free, web-based application that allows financial institutions supervised by the Federal Reserve, as well as their authorized agents such as law firms, to submit certain applications and other filings electronically. Using E-Apps may reduce an institution’s copying and other costs incidental to providing multiple hard copies of filings and help streamline some of the Federal Reserve’s internal procedures. However, filing through E-Apps will not shorten the relevant review period for any application or other filing.
Signing up
Each organization, whether a financial institution, law firm or other agent, starts the registration process by completing and submitting to the Federal Reserve both an Authorizer Designation form and a Credential Request form (accessible from the Federal Reserve’s E-Apps website). The Authorizer Designation establishes an agent official (AO), the person within an organization responsible for approving the requests of any other individuals for filing credentials. The Credential Request form is submitted by each individual subscriber seeking the secure credentials to access the E-Apps system. After receiving the Credit Request form, the Federal Reserve will issue an authorization code to the AO and a separate reference code to the individual subscriber. The subscriber needs both codes in order to download the security certificate, which is then used to verify the subscriber’s identity for secure access to the E-Apps system. If a financial institution desires to appoint an agent to submit filings on its behalf, it must also complete and submit an Agent Appointment letter, after which the institution will be listed on the authorized agent’s log-in information as an institution for which the agent is authorized to submit filings. The Federal Reserve’s Customer Contact Center is a helpful resource in fielding questions about or troubleshooting the registration process.
E-Apps Filings
Once fully registered, a subscriber may submit filings 24 hours a day, although any filing received after 3 p.m. in the time zone of the relevant Federal Reserve Bank is deemed to be filed on the next business day. This filing accessibility provides additional flexibility for institutions during hectic transactions. The Federal Reserve is encouraging the use of E-Apps, and most filings can be submitted through the system, although all filings may still be accepted in hard copy. A complete list of filings permitted through E-Apps is provided on the Federal Reserve’s website, and more details are also contained in FAQs, including permitted electronic formats for filings and the E-Apps experts at each local Federal Reserve Bank ().
Closing Thoughts
If your institution and your law firm or other consultants have not yet registered to use the E-Apps system, you may want to do so before you have a transaction or other filing you need to submit to the Federal Reserve. We have found E-Apps to be an efficient way to submit your required filings and, by registering in advance, you will be prepared if or when you want to use it.
