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Recasting the viewpoint of brokered deposits in light of changing regulatory considerations and technological innovation.
The FDIC revised the definitional criteria for determining brokered deposit populations in light of the rapid pace of technological innovation and digital customer interaction as well as the entrant of FinTechs in bank relationships. The new definition requires a fresh look at the reporting of deposit populations; concurrent assessments of relationship profitability and pursuit of designated and requested exceptions are essential to mitigating unfavorable impact.
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The author would like to thank Alan Zimmerman, John Lothman, Tom Godsey and Jacob McCoy for their contributions in developing this brief.
Summary
Regulatory change in the framework for defining and evaluating brokered deposits remains complex; consideration of the new requirements and avenues for relief is essential.
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