News & Analysis as of

Financial Institutions Brokered Deposits

Troutman Pepper

Brokered Deposits Rule Threatens to Upend Bank Balance Sheets

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“In the worst case, these [newly designated brokered deposits] will have to get offloaded in a way that potentially puts those banks at even greater liquidity risk, especially to the extent that they have a higher...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

Alston & Bird

FDIC Proposes Rule to Revise Brokered Deposit Regulations and Issues Request for Information on Deposit Data

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In a proposed rule and information request, the Federal Deposit Insurance Corporation expressed its concerns with the current brokered deposit restrictions and reporting requirements. Our Financial Services Team zeroes in on...more

Venable LLP

FDIC Rethinks Brokered Deposits, Again

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The FDIC recently proposed a rule that would substantially change the 2020 final rule on brokered deposits that largely liberalized the FDIC’s framework. The proposed rule would eliminate many of the changes from 2020 and...more

Troutman Pepper

Bank Allies Say FDIC Brokered Deposit Plan Reflects Outdated Thinking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

Mayer Brown

Regulatory Redux: FDIC Proposes Brokered Deposit Revisions

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On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...more

Troutman Pepper

Turning Back the Clock: FDIC Proposes Significant Changes to 2020 Brokered Deposit Rule

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On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s...more

Goodwin

FDIC Proposes Overhaul to Brokered Deposit Classification Rules; Significant Impact to Banking as a Service (BaaS) Industry

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On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would make significant revisions to the FDIC’s regulations implementing the provisions of Section 29 of the Federal Deposit...more

Ballard Spahr LLP

FDIC Proposes Revisions to Broker Deposits Rule

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The FDIC board on July 30 approved a notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered deposits (12 CFR 337.6)....more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2024

The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more

Cadwalader, Wickersham & Taft LLP

New Guidance from the FDIC on Brokered Deposits Affects Insured Depository Institutions

On July 15, the Federal Deposit Insurance Corporation (“FDIC”) issued an updated Q&A regarding how companies involved in managing deposits can determine whether such deposits should be considered brokered, and/or whether they...more

Locke Lord LLP

FDIC Launches Brokered Deposit Resource Webpage and ‎Provides Guidance for Expedited Processing of Notices for ‎Designated...

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Effective April 1, 2021, the Federal Deposit Insurance Corporation (“FDIC”) launched a “Brokered Deposit” bankers’ resource web page, concurrently with the effective date of its final rule ‎‎(the “Rule”)‎ to modernize the...more

Alston & Bird

FDIC Approves Final Rule on Brokered Deposits

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Our Financial Services & Products Group unpacks the Federal Deposit Insurance Corporation’s most significant changes to brokered deposit regulations since 1989....more

Latham & Watkins LLP

US Federal Banking Agencies Introduce Further Measures to Address Continuing COVID-19-Related Risks

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The three US federal banking agencies continue to take additional steps to promote the functioning of the financial system in the face of the pandemic. The three US federal banking agencies - the Board of Governors of the...more

K&L Gates LLP

The FDIC Considers Modernizing its Brokered Deposit Rules

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Brokered deposits is a hot topic once again. On December 19, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) published an advance notice of proposed rulemaking and request for comment on possible updates to its...more

Orrick - Finance 20/20

FDIC Issues Final Rule on Reciprocal Deposits and Seeks Comments on Brokered Deposits and Interest Rate Restrictions

On December 19, the Federal Deposit Insurance Corporation (“FDIC”) “…adopted a final rule related to the treatment of reciprocal deposits, and it also issued an advance notice of proposed rulemaking [] related to brokered...more

Ballard Spahr LLP

FDIC seeking comment on brokered deposit and interest rate regulations

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The FDIC has issued an Advance Notice of Proposed Rulemaking (ANPR) seeking comment on its regulatory approach to brokered deposits and interest rate restrictions. ...more

Ballard Spahr LLP

House members request reconsideration of FDIC brokered deposits interpretation

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Last week, Representative Blaine Luetkemeyer, Chair of the House Financial Services Committee’s Subcommittee on Financial Institutions and Consumer Credit, and Representative Scott Tipton sent a letter to Jelena McWilliams,...more

Goodwin

Financial Services Weekly News - July 2016

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Regulatory Developments - NY DFS Adopts Final Anti-Terrorism Program Regulation - On June 30, New York’s Department of Financial Services (DFS) adopted a risk-based anti-terrorism and anti-money laundering...more

Manatt, Phelps & Phillips, LLP

Tweaking FAQs on Brokered Deposits, FDIC Seeks Public Input

Why it matters The Federal Deposit Insurance Corporation (FDIC) is proposing to update its Frequently Asked Questions (FAQs) on identifying, accepting, and reporting brokered deposits, and is requesting public comment on...more

Locke Lord LLP

FDIC Seeks Comment on Brokered Deposit FAQs

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On November 13, 2015, the Federal Deposit Insurance Corporation (FDIC) issued Financial Institution Letter 51-2015 (FIL-51-2015), FDIC Seeking Comment on Frequently Asked Questions Regarding Identifying, Accepting and...more

Manatt, Phelps & Phillips, LLP

Industry Groups Express Concern About FDIC Guidance on Brokered Deposits

Why it matters - What is the proper scope of the definition of a "brokered deposit"? Certain industry groups wrote a letter to the Federal Deposit Insurance Corp. (FDIC) expressing concern about the broadened definition...more

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