B3 - Are there instances when facilitating the placement of deposits or placing deposits would not be considered the brokering of deposits?

Compliance > Deposits > Brokered Deposits
Q:  Are there instances when facilitating the placement of deposits or placing deposits would not be considered the brokering of deposits?
 
A:    Yes.  For example, one of the exceptions to the definition of “deposit broker” is the “trustee of a pension or other employee benefit plan, with respect to funds of the plan.”    Under this exception, the trustee is not classified as a deposit broker even if the trustee places the plan’s deposits (or facilitates the placement of the plan's deposits) at an insured depository institution.


This can be found in FDIC’s "Identifying, Accepting and Reporting Brokered Deposits Frequently Asked Questions," which can be found at https://www.fdic.gov/news/news/financial/2016/fil16042b.pdf
 

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