Understand how a bank or broker should navigate some of the most common pitfalls in applying FDIC regulations to your business.
Almost $2 trillion of customer funds are currently maintained in deposit accounts at FDIC-insured banks that are offered by and held through registered broker-dealers and banks that act as deposit brokers. These brokered deposits are, on one hand, a core investment and savings product for retail investors and other customers of financial services firms, and, on the other, a significant source of funding for banks, which can access a nationwide capital market by attracting or tapping into brokered deposits. A year ago, the FDIC made the most far-reaching changes to the definition of deposit broker since its brokered deposit regulations were adopted in 1992. These amendments, among many other changes, expand existing exceptions to the deposit broker definition and create several new exceptions. In this course, you will get an overview of the new brokered deposit regulations, learn guidance the FDIC staff has provided about them, and understand how a bank or broker should navigate some of the most common pitfalls in applying these regulations to your business.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Background: The Brokered Deposit Market
- Definitions and Statutory Exemptions
- Discussion of Brokered Deposits Markets (CDs/Bank Liquidity/Sweeps)
- Consequences of Brokered Deposits (Call Reports/LCR)
Longstanding Issues in the Brokered Deposit Regulatory Regime
- Brief History (Emergence of Definition; FDIC's Evolution and Studies)
- Common Issues Encountered:
- PassThrough Insurance
- General Securities Laws Issues/Structure
- SEC Sweep Guidelines
New Regulations
- Summary of Rules and Requirements, With a Focus on Key Practice Points
- Notice Requirement for 25% and Facilitating Payments Exceptions
- Matchmaking
- Assets Under Administration and Business Line Definitions
- FDIC DeEmphasis on Fees
- Other New PPE Exceptions
- Exclusive Deposit Placement Arrangements
- Other Issues
- New FAQ Guidance
- A Year on, Tension Between the Final Rule and Subsequent FDIC Staff Interpretation of the Rule
Trends and the Future
- Fintech Products/Neobanks
- In-House Broker Sweep Programs
- Increase in Interest Rates = Return of CDs?
- Stablecoins
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on February 28, 2022.
Call 1-866-352-9540 for further credit information.
- AK CLE 1.0
- Alaska attorneys may receive 1.0 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
- AL CLE 1.1
- This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.1 hours credit.
- Arizona CLE 1.0
- The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.0 hours toward your annual CLE requirement for the State Bar of Arizona.
- CA MCLE 1.0
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.0 CLE hours of participatory credit.
- CT CLE 1.0
- Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.0 CLE credit(s).
- GA CLE 1.0
- This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.0 CLE hours.
- MO CLE 1.3
- This course qualifies for self-study CLE credit in Missouri.
- NM CLE 1.1
- This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.1 hours of credit.
- RI CLE 1.0
- This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.0 hours of CLE credit.
- VT CLE 1.0
- This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.0 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Nathan Brownback
Seward & Kissel LLP
Nathan S. Brownback
- Associate in Seward & Kissel’s Financial Services Regulatory Group, in their Washington D.C. office
- Practice focuses on the regulation of domestic and foreign banks, with particular emphasis on the regulation under the Dodd-Frank Act, including the Volcker Rule
- Co-authored the United States chapter of the 2022 edition of Lexology, Getting the Deal Through: Fintech, which provides a summary of key aspects of United States fintech law, and he is a contributor to Seward & Kissel’s Cryptocurrency and Blockchain blog, SKrypto
- Served as a law clerk for Judge Richard T. Morrison on the U.S. Tax Court
- Prior to receiving his law degree, he was an economic research analyst, first in the private sector and subsequently for a regional Federal Reserve Bank
Casey Jennings
Seward & Kissel LLP
- Counsel in the Washington, D.C. office of Seward & Kissel LLP
- Previously a counsel in the Office of Regulations at the Consumer Financial Protection Bureau
- Nationally recognized expert in the structuring of deposit products and regularly advises banks, credit unions, broker-dealers, and financial technology providers on the offering of consumer deposit accounts and certificates of deposit.
- Relevant experience includes advising on the design of TISA-compliant account opening procedures, and deposit brokers on the application of TISA advertising requirements. Also advised broker-dealers on regulatory compliance related to deposit accounts held through intermediaries, investment funds, and managers regarding the bank resolution process and treatment of accounts; and major broker-dealers on the structuring of sweep programs and reciprocal deposit arrangements
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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