Late last month, the Federal Deposit Insurance Corporation (FDIC) hosted an informational call (the Industry Call) to discuss certain questions raised by industry participants in response to the FAQ guidance issued by the FDIC regarding brokered deposits (the Guidance or FAQs).1 The Guidance answers a wide range of questions regarding the classification of certain deposits as “brokered” and the implications of such a classification.
Subjects of the FAQs include “facilitation” generally, bank networks, listing services, prepaid and debit cards, timing of acceptance of deposits and interest rate restrictions. The FAQs conclude that the deposits at issue in many of the questions presented are brokered, which in some cases would appear to represent a departure from industry understanding and/or practice. However, the FDIC staff noted on the Industry Call that the FAQs were not intended to introduce new guidance.
