Saying that its proposed brokered deposits rule would have “significantly disrupted many aspects of the deposit landscape,” the FDIC has withdrawn the proposal. ...more
On March 3, 2025, the Federal Deposit Insurance Corporation (“FDIC”) withdrew its pending proposed rule on brokered deposits (the “Proposal”), originally published in the Federal Register on August 23, 2024. The Proposal,...more
James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the March 5, 2025 Banking Dive article, “FDIC Withdraws Merger Policy, Brokered Deposits Proposal.”...more
The FDIC has signaled the reversal of key, controversial proposals from 2024. In doing so, it has provided welcome clarity on important areas that implicate banks of various sizes and charter types, allowing banks to focus on...more
On January 20, the FDIC appointed Travis Hill as Acting Chairman. In a prepared statement the next day, Hill outlined his agenda to address changes at the Corporation. Among other efforts, he announced a wholesale review of...more
This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape. In this edition: CFPB issues final rule on personal financial data rights...more
Yesterday, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all...more
“In the worst case, these [newly designated brokered deposits] will have to get offloaded in a way that potentially puts those banks at even greater liquidity risk, especially to the extent that they have a higher...more
A group of 11 financial services associations is calling on the FDIC to withdraw its notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered...more
In a proposed rule and information request, the Federal Deposit Insurance Corporation expressed its concerns with the current brokered deposit restrictions and reporting requirements. Our Financial Services Team zeroes in on...more
The FDIC recently proposed a rule that would substantially change the 2020 final rule on brokered deposits that largely liberalized the FDIC’s framework. The proposed rule would eliminate many of the changes from 2020 and...more
“Hot money” – as it was later dubbed – was viewed by skeptics as one of the major causes of the savings and loan crisis of the 1980s....more
On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...more
On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s...more
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would make significant revisions to the FDIC’s regulations implementing the provisions of Section 29 of the Federal Deposit...more
The FDIC board on July 30 approved a notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered deposits (12 CFR 337.6)....more
The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more
On July 15, the Federal Deposit Insurance Corporation (“FDIC”) issued an updated Q&A regarding how companies involved in managing deposits can determine whether such deposits should be considered brokered, and/or whether they...more
Effective April 1, 2021, the Federal Deposit Insurance Corporation (“FDIC”) launched a “Brokered Deposit” bankers’ resource web page, concurrently with the effective date of its final rule (the “Rule”) to modernize the...more
Our Financial Services & Products Group unpacks the Federal Deposit Insurance Corporation’s most significant changes to brokered deposit regulations since 1989....more
The three US federal banking agencies continue to take additional steps to promote the functioning of the financial system in the face of the pandemic. The three US federal banking agencies - the Board of Governors of the...more
Brokered deposits is a hot topic once again. On December 19, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) published an advance notice of proposed rulemaking and request for comment on possible updates to its...more
On December 19, the Federal Deposit Insurance Corporation (“FDIC”) “…adopted a final rule related to the treatment of reciprocal deposits, and it also issued an advance notice of proposed rulemaking [] related to brokered...more
The FDIC has issued an Advance Notice of Proposed Rulemaking (ANPR) seeking comment on its regulatory approach to brokered deposits and interest rate restrictions. ...more
Last week, Representative Blaine Luetkemeyer, Chair of the House Financial Services Committee’s Subcommittee on Financial Institutions and Consumer Credit, and Representative Scott Tipton sent a letter to Jelena McWilliams,...more