FDIC Updates FAQ on Brokered Deposits

The FDIC today finalized updates to its frequently asked questions on identifying, accepting, and reporting brokered deposits. The FDIC’s views on brokered deposits remain very broad, with the result that most deposits involving a third party will be considered brokered.

However, the agency said it “recognizes that brokered deposit determinations are fact-specific” and that it would thus “consider these determinations on a case-by-case basis.” The agency encouraged bankers to contact FDIC offices with questions and emphasized that institutions that need to reclassify deposits as brokered would generally not need to refile past Call Reports.

The FDIC first issued FAQs on brokered deposits a year and a half ago, causing widespread confusion at banks as it seemed to broaden the scope of deposits deemed brokered. In response to ABA’s concerns, the FDIC promised to update the FAQs as needed. ABA staff worked closely with the FDIC to seek needed clarifications, such as which prepaid card and government benefit card deposits are brokered and what is required for deposits from affiliated companies and related employees. For more information, contact ABA’s Alison Touhey.