Home / Bank Activities and Structure/ Comment Letters/ FDIC

BPI Submits Recommendations to Clarify and Modernize FDIC’s Approach to Brokered Deposits

Print
BPI Submits Recommendations to Clarify and Modernize FDIC’s Approach to Brokered Deposits

On May 6, the Bank Policy Institute (BPI) submitted a comment letter responding to the FDIC’s Advance Notice of Proposed Rulemaking addressing the FDIC’s comprehensive review of its regulatory approach to brokered deposits.  In the letter, BPI recommends that the FDIC clarify and modernize its approach to brokered deposits in a manner that is consistent with Congress’ purpose in the statute.

The letter recommends the FDIC:

  • Expressively clarify that dual-hatted, dual and affiliate employees are not “deposit brokers”;
  • Revise its treatment of marketing and advertising relationships and referral arrangements to reflect innovations in technology and marketing methods;
  • Exclude affiliate-generated investment sweep deposits from classification as brokered;
  • Exclude deposits generated through operating subsidiaries from being classified as brokered; and
  • Reconsider its treatment of deposits associated with prepaid cards.
Download
You Might Also Be Interested In...
Bank Activities and Structure capitol hill building BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
Bank Activities and Structure capitol hill building BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Financial Institutions and Monetary Policy
Bank Activities and Structure Coalition of Trades Comment on Negative Implications of SEC Custody Rule
Custody Services The Lone Ranger in a Town Full of Sheriffs: How the SEC’s Aggressive Agenda Interferes with the Business of Banking
Resolution & Recovery Planning BPI Responds to FDIC Special Assessment Rulemaking
Resolution & Recovery Planning FDIC Special Assessment Proposal Lacks Analysis and Needs Adjustment to Avoid Unintended Side Effects
Patent Reform capitol hill building BPI and Coalition of Trades Comment on U.S. Patent and Trademark Office Proposal
Bank Activities and Structure capitol hill building BPI Statement Before House Oversight & Accountability Committee’s Subcommittee on Health Care and Financial Services
More Posts by This Author
Announcements BPI Welcomes U.K. Attorney Samantha Riley to Regulatory Affairs Team
Bank Capital and Stress Testing U.S. Bank Capital Levels: Aligning With or Exceeding Midpoint Estimates of Optimal
Newsletters BPInsights: September 16, 2023
Central Bank Digital Currency BPI’s Paige Pidano Paridon Testifies on CBDC Before House Subcommittee
Bank Activities and Structure capitol hill building BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
Bank Activities and Structure capitol hill building BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Financial Institutions and Monetary Policy
Basel Finalization BPI’s Greg Baer Testifies on Basel Endgame Before House Financial Services Subcommittee
Bank Activities and Structure Coalition of Trades Comment on Negative Implications of SEC Custody Rule