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ICBA published a guide to help community bankers submit unique comment letters on the FDIC’s notice of proposed rulemaking on brokered deposit restrictions.
About the Proposal: The FDIC is inviting comments on proposed revisions to its regulations relating to brokered deposits restrictions. Although the FDIC finalized revisions to its brokered deposits regulations in 2020, the agency now proposes to reverse significant aspects of the 2020 framework. If finalized, more deposits would be considered brokered deposits under the proposal and fewer deposits would be considered core deposits.
Potential Impact: While the proposal does not make changes to the ICBA-advocated S. 2155 community bank thresholds Congress enacted in 2018 for reciprocal non-brokered deposits, it could negatively affect community banks’ access to funding sources, liquidity management strategies, and deposit funding costs. Additionally, the proposal could impair community banks’ abilities to structure deposit placements to maximize deposit insurance coverage for their customers.
ICBA Guide: ICBA’s grassroots guide offers details on the proposal, sample responses to various issues raised by the proposal, and instructions on submitting comments.
Deadline: Comments are due Thursday, Nov. 21.