On May 6, BPI submitted a comment letter to the FDIC responding to the agency’s Advance Notice of Proposed Rulemaking addressing the FDIC’s comprehensive review of its regulatory approach to brokered deposits.
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.