Q: Do companies or organizations that provide marketing for an insured depository institution, in exchange for volume-based fees, qualify as deposit brokers because they are facilitating the placement of deposits?
A: Yes. Some insured depository institutions attempt to attract new depositors through advertising or referrals by third parties (such as nonprofit affinity groups as well as commercial enterprises), in exchange for volume-based fees. In these cases, the FDIC has taken the position that the third party is “facilitating the placement of deposits” by connecting the depository institution with new account holders. Hence, the third party is a deposit broker, and the deposits would be brokered.