Late last year, the FDIC released guidance on brokered deposits in the form of a series of frequently asked questions and answers (FAQs). The guidance is available here: https://www.fdic.gov/news/news/financial/2015/fil15002a.pdf
The ostensible purpose of the guidance is to collect previously scattered views on various questions related to two primary subjects: what are brokered deposits and how they should be reflected on bank call reports. Brokered deposits impact assessments for deposit insurance. For some institutions, the FAQs may have little impact but for others the FAQs will be important and required reading.
Although the FDIC called the release “guidance,” some commentators have suggested the material contains the first expression by the agency on a number of issues, including in particular further discussion on an important exception to the definition of deposit broker, the so-called “primary purpose exception” discussed below.… Continue Reading