B5 - Do third parties that design deposit products, such as deposit accounts with special features, qualify as deposit brokers?

Compliance > Deposits > Brokered Deposits
Q:  Do third parties that design deposit products, such as deposit accounts with special features, qualify as deposit brokers?
 
A:    Some third parties design deposit products with special features, such as deposit accounts that produce interest or rewards based on account activity.  If a company merely designs deposit products or deposit accounts for one or more banks, without placing deposits or facilitating the placement of deposits at these banks, the company will not be classified as a deposit broker.  However, as discussed in B4, if a company also markets the bank’s deposit products in exchange for volume-based fees, then it would be a deposit broker, and the deposits would be brokered.


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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