FDIC Adopts New Recordkeeping Requirements for Large Banks – Modifies Original Proposal as to Brokered CDs -

In November 2016, the FDIC approved a final rule establishing recordkeeping requirements for insured institutions with a large number of deposit accounts. The rule is intended to facilitate rapid payment of insured deposits to customers if the institutions fail.

Broker-dealers who sell structured CDs and other forms of brokered CDs will most likely be pleased that the FDIC revised some of the proposed provisions that would have been the most challenging in connection these types of products.