News & Analysis as of

Final Rules Brokered Deposits

Troutman Pepper Locke

FDIC Withdraws Merger Policy, Brokered Deposits Proposal

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James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the March 5, 2025 Banking Dive article, “FDIC Withdraws Merger Policy, Brokered Deposits Proposal.”...more

Ballard Spahr LLP

Trade Groups Call on FDIC to Withdraw Brokered Deposit NPRM

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A group of 11 financial services associations is calling on the FDIC to withdraw its notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered...more

Troutman Pepper Locke

FDIC’s Brokered Deposit Proposal Expected to Face Industry Pushback

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Currently, deposit accounts enabling payment transactions are automatically non-brokered, but the new rule will eliminate this designation, meaning parties relying on the “enabling transactions” exception will have to go...more

Davis Wright Tremaine LLP

Is the FDIC's Proposed Rulemaking on Brokered Deposit Restrictions a Solution in Search of a Problem?

One of the most fundamental activities of an insured depository institution (IDI) is taking and safekeeping customer deposits. However, a recent proposed rulemaking by the Federal Deposit Insurance Corporation (FDIC) poses...more

Troutman Pepper Locke

Bank Allies Say FDIC Brokered Deposit Plan Reflects Outdated Thinking

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“Hot money” – as it was later dubbed – was viewed by skeptics as one of the major causes of the savings and loan crisis of the 1980s....more

Ballard Spahr LLP

FDIC Announces New Resources For Brokered Deposits Regulation

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On April 1, 2021, the FDIC’s final rule issued in December 2020 revising its brokered deposits regulation became effective. The full compliance date for the final rule is January 1, 2022. The rule established a new...more

Morrison & Foerster LLP

FDIC Brokered Deposits Final Rule: Key Aspects For Broker Dealers

On January 22, 2021, the Federal Deposit Insurance Corporation (“FDIC”) published its final rule (“Final Rule”) revising and modernizing its regulations related to brokered deposits and the interest rate restrictions that...more

Troutman Pepper Locke

FDIC Issues Final Rule to Modernize Brokered Deposit Regulation and Refines the Primary ‎Purpose Exception

Troutman Pepper Locke on

On December 15, 2020, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule ‎‎(the “Rule”)‎ ‎ to modernize its regulations that implement Section 29 of the Federal Deposit ‎Insurance Act (“FDI Act”). The FDIC...more

Ballard Spahr LLP

FDIC issues final rule on brokered deposits and interest rate limits applicable to less than well capitalized institutions

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The FDIC has issued a final rule that establishes a new framework for analyzing whether deposits made through deposit arrangements qualify as “brokered deposits” and amends the methodology for calculating the interest rate...more

Troutman Pepper Locke

FDIC’s Final Rule on Brokered Deposits Adds Clarity to Fintech Partnerships and Other Common Arrangements

Troutman Pepper Locke on

On December 15, the Federal Deposit Insurance Corporation (FDIC) issued a final rule (Final Rule) establishing a new framework for analyzing whether bank deposits obtained through third-party arrangements are brokered...more

Goodwin

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

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In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

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