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.
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