Live Webinar

65-minute live streaming program
  • February 28
  • 1:00 - 2:05 pm EST

FDIC Guidance on Bank Brokered Deposits

February 28

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.

Learning Objectives

  • You will be able to discuss brokered deposits markets.
  • You will be able to explain the consequences of brokered deposits.
  • You will be able to review new PPE exceptions.
  • You will be able to describe new trends, including neobanks and stablecoins.

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Why Lorman?

Over 35 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:
    • Pass-Through 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 De-Emphasis 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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More Program Information

Why Lorman?

Over 35 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

Live Webinar Registration

  • 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.
     
  • AR CLE 1.0
     
  • This course has been approved for 1.0 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.0
     
  • The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. 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 Business Center, LLC. 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).
     
  • HI CLE 1.0
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.0 CLE credit hours.
     
  • IL CLE 1.0
     
  • This course was approved for a total of 1.0 hours of MCLE Credit by the Illinois MCLE Board.
     
  • NH MCLE 1.0
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 60 Minutes.
     
  • NJ CLE 1.3
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.3 hours of total CLE credit.
     
  • NY CLE 1.0 including Areas of Professional Practice 1
     
  • This course has been approved in accordance with the requirements of the New York Continuing Legal Education Board for up to a maximum of 1.0 credit hours in the area(s) of Areas of Professional Practice for 1.00 hour. Each hour may be counted only as satisfying one category of credit. Duplicate credit for the same hour of instruction is not permitted. This course qualifies for both established and newly admitted attorneys. Lorman Business Center, LLC. has a financial hardship guideline. Please contact customer service at 1.866.352.9539 for instructions on how to apply.
     
  • PA CLE 1.0
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.0 hours of substantive law, practice and procedure CLE 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 program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.0 hours of CLE credit.
     
  • WI CLE 1.0
     
  • This program has been approved by the Board of Bar Examiners for 1.0 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 1.3
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.3 MCLE hours.
     
  • CPE 1.2
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 1.2 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: . Prerequisite: basic knowledge of the banking industry. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     

Who should attend?

This live webinar is designed for attorneys, presidents, vice presidents, branch managers, lending and loan officers, mortgage brokers, accountants, and loan department personnel.

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More Program Information

Why Lorman?

Over 35 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

Nathan Brownback

Seward & Kissel LLP

  • Associate in Seward & Kissel LLP’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
  • 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
  • Contributor to Seward & Kissel’s Cryptocurrency and Blockchain blog, SKrypto
  • 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
Casey Jennings

Casey Jennings

Seward & Kissel LLP

  • Member of Seward & Kissel LLP’s Financial Services Regulatory Group and Blockchain and Cryptocurrency Group in their Washington, D.C. office
  • Regularly provides legal aid to clients with respect to financial matters such as deposit issues, lending services, state and federal licensing and registration, anti-money laundering, custody, transfer, payments, and liquidity issues, and the Bank Holding Company Act
  • A primary focus of his practice is structuring new financial products, including FDIC-insured deposit products (including brokered deposits and deposits exempt from classification as brokered) and virtual financial products (including securities tokens, utility tokens, and stablecoins)
  • Joined the firm from the Consumer Financial Protection Bureau where he developed and implemented a financial regulatory policy with a focus on unfair, deceptive, and abusive acts and practices (UDAAP), electronic fund transfers, truth in lending, qualified mortgages, fair credit reporting, and data privacy and security
  • Law clerk for the Honorable James C. Turk, Senior United States District Judge for the Western District of Virginia
  • Contributor to Seward & Kissel LLP’s Cryptocurrency and Blockchain blog, SKrypto, and also moderated the firm’s recent Blockchain Symposium
  • 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
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Why Lorman?

Over 35 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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Product ID: 409433
Published 2022
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