The FDIC updated its controversial FAQs on identifying, accepting, and reporting brokered deposits and sought comment on the revisions.
The document was originally issued in January and caused widespread confusion and frustration at banks as it seemed to broaden the scope of deposits deemed “brokered.” In response to ABA’s concerns, FDIC staff encouraged banks to reach out to their examiners with specific questions about the guidance’s impact on depository operations, and it promised to update the FAQs as needed.
The changes proposed, which are detailed in a “track changes” version of the document, include both clarifications and new questions on topics like prepaid cards, referrals from insurance agents, lawyers and accountants, government benefits disbursed through cards and restrictions on banks that cease to be well capitalized for prompt corrective action purposes.
The FDIC stressed that the document is “a plain language summary of previously issued guidance that is conveniently located in one place,” and it added footnotes throughout the document to site previously issued opinions. Comments on the FAQs and introductory letter are due Dec. 28.