The Clearing House Association (TCH) along with the American Bankers Association and the Institute of International Bankers submitted a letter to the FDIC commenting on the FDIC’s January 2015 guidance and FAQs about what constitutes a ‘brokered deposit’. The letter expresses concern about the potential over-breadth of the guidance and requests that the FDIC clarify various items, principal among which is that deposits should not be considered brokered if they result from client‐servicing activities performed by dual, contract, and affiliate employees in connection with those employees’ providing a “one stop shop,” full‐service banking experience to customers, where the employees’ compensation is not directly or explicitly tied in any material respect to the volume of deposits placed.
You Might Also Be Interested In...
Bank Activities and Structure
BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
Bank Activities and Structure
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
More Posts by This Author
Bank Capital and Stress Testing
U.S. Bank Capital Levels: Aligning With or Exceeding Midpoint Estimates of Optimal
Central Bank Digital Currency
BPI’s Paige Pidano Paridon Testifies on CBDC Before House Subcommittee
Bank Activities and Structure
BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
Bank Activities and Structure
BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Financial Institutions and Monetary Policy