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FDIC Finalizes Changes to Brokered Deposit Regulations
21 December 2020
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On December 15, 2020, the Federal Deposit Insurance Corporation approved a final rule that establishes a new framework for analyzing whether deposits are classified as brokered deposits.
The final rule introduces a regulatory test for when a person would be regarded as in the business of placing, or facilitating the placement of, deposits.
The final rule also establishes a new framework and application process for evaluating the applicability of the primary purpose exception as well as several “designated exceptions” covering a broad range of business relationships that will be deemed to qualify for the primary purpose exception without a formal application to the FDIC.
Satish M. Kini
Gregory J. Lyons
Alexandra N. Mogul
David C. Saltzman
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