United States:
Federal Register: FDIC Proposes Revisions To Brokered Deposit Regime
17 February 2020
Cadwalader, Wickersham & Taft LLP
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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.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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