FDIC updates brokered deposit FAQs
AML AND COMPLIANCE NEWS |
The Federal Deposit Insurance Corporation (FDIC) has revised its Frequently Asked Questions (FAQs) relating to brokered deposits. Financial Institution Letter, FIL 42-2016, which announces the updated FAQs, supersedes FIL 2-2015 and FIL 51-2015.
The FAQs are based on statute, regulation, published advisory opinions and the FDIC’s 2011 Study on Core Deposits and Brokered Deposits and comments to the proposed FAQs. Revised FAQs were originally issued in January 2015; these final FAQs include the majority of those proposed updates, as well as some clarifications and new FAQs. Items addressed in the FAQs include:
- Business professionals and deposit referral programs
- Deposits gathered through dual employees, call center employees or contractors
- Deposits underlying government-sponsored prepaid or debit card programs
- Treatment of certain non-maturity deposits
The FDIC will continue to accept and consider, on a case-by-case basis, individual requests on brokered deposit determinations, and will issue additional advisory opinions as it deems appropriate. The FAQs will continue to be updated periodically.