FDIC Updates on Brokered Deposits

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Summary:&#13

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The Federal Deposit Coverage Company (FDIC) is issuing a assertion, including a new Query and Reply (Q&A), and updating public info on the Banker Useful resource Centre Brokered Deposits Web page, to remind FDIC-insured depository establishments (IDIs) that deposits swept from broker sellers with a major reason exception to unaffiliated IDIs should be documented as brokered if there are any extra 3rd functions concerned that qualify as a deposit broker, as outlined by Section 337.6 –Brokered Deposits, of the FDIC’s Rules and Restrictions.

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The FDIC Assertion can be uncovered on the FDIC web-site.

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See FDIC’s Banker Source Middle Brokered Deposits Site for the new Q&A and supplemental information and facts.

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Assertion of Applicability: The contents of, and content referenced in, this FIL use to all FDIC-insured economical institutions.

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Highlights:&#13

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  • A Assertion, new Q&A (D.10) in the Questions and Answers Connected to Brokered Deposit Rule, and an update to the Public Report of Entities Publishing Notices for a Key Function Exception asterisk take note, are remaining issued to remind IDIs that:
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    • An IDI acquiring sweep deposits from an unaffiliated broker vendor with a most important purpose exception for that organization line really should be knowledgeable of any additional 3rd events involved in the deposit placement arrangement that qualify as a deposit broker
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    • If an additional third party is concerned that would qualify as a deposit broker, for example, the third celebration is participating in matchmaking things to do, then the sweep deposits obtained from the broker vendor need to be reported as brokered deposits on the IDI’s quarterly filings of the Consolidated Report of Affliction and Revenue (Call Report), even if the broker vendor has a key objective exception for the related business enterprise line
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    • In conjunction with new Q&A D.10, IDIs must evaluation Q&A C.6 for an instance of companies that constitute matchmaking actions when provided by a third get together to a broker-seller in an unaffiliated sweep program and
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    • The IDI is dependable for correctly reporting deposits on its Simply call Report. However, the FDIC will not need an IDI to refile Call Experiences that predate the issuance of the attached Assertion, if, after fantastic faith efforts, specific deposits have been not earlier noted as brokered by the IDI thanks to a misunderstanding of how the facilitation facet of the deposit broker definition applies when additional 3rd parties are associated.&#13
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  • Simply call Report instructions have been up to date to supply that IDIs that get deposits from a human being with a most important goal exception ought to be knowledgeable if any added third get-togethers that qualify as deposit brokers are concerned in the deposit placement arrangement, and if so, those deposits must be described as brokered.
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  • The Public Report of Entities Publishing Notices for a Primary Objective Exception has also been updated to contain filings been given by way of June 24, 2022.
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  • Interested events can indicator up to acquire alerts when the Brokered Deposits site is up-to-date as a result of the FDIC Subscription Services.
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Issues and Responses Relevant to Brokered Deposits Rule – As of July 15, 2022

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Connected Subject:

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Brokered Deposits

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Relevant Resources:

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12 CFR §§ 303.243 and 337.6 – Brokered Deposits

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FIL-113-2020, Merged Last Rule on Brokered Deposits and Insurance coverage Amount Restrictions

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Banker Resource Heart Brokered Deposits Site

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