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ARTICLE · 13 JANUARY 2020

FDIC Proposes Changes To Brokered Deposits Restrictions

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On December 12, 2019, the Federal Deposit Insurance Corporation ("FDIC") proposed revisions to the restrictions on brokered deposits (the "Proposal").11 The Proposal is intended to modernize the FDIC

United StatesFinance and Banking
Bradley Berman
Bradley Berman
Matthew Bisanz
Matthew Bisanz
Gonzalo Go
Gonzalo Go
Lawrence Hamilton
Lawrence Hamilton
Anna T. Pinedo
Anna T. Pinedo
Remmelt Reigersman
Remmelt Reigersman
Brennan W. Young
Brennan W. Young
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On December 12, 2019, the Federal Deposit Insurance Corporation ("FDIC") proposed revisions to the restrictions on brokered deposits (the "Proposal").11 The Proposal is intended to modernize the FDIC's framework for brokered deposits, and would revise both the substantive regulations for brokered deposits and the procedures for requesting exceptions and filing reports.

The Proposal would narrow the scope of the brokered deposits regulation by (i) more explicitly defining who is a deposit broker and (ii) expanding the exclusions for putative brokers that are subsidiaries of the insured depository institution or operate with a primary purpose other than placing funds at depository institutions (the "Primary Purpose Exception").

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