ARTICLE
17 February 2020

Federal Register: FDIC Proposes Revisions To Brokered Deposit Regime

CW
Cadwalader, Wickersham & Taft LLP

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The FDIC proposal to revise its brokered deposit regime was published in the Federal Register.
United States Insurance

The FDIC proposal to revise its brokered deposit regime was published in the Federal Register. Comments on the proposal must be submitted by April 10, 2020.

The amendments would establish a new framework for analyzing certain provisions of the "deposit broker" definition, including what constitutes "facilitating the placement of deposits" and the circumstances in which the "primary purpose exception" apply (see prior coverage). The proposal would also establish an application process for insured depository institutions and third parties that seek to use the primary purpose exception.

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