B6 - Are insurance agents, lawyers, or accountants that refer clients to a bank considered to be deposit brokers?

Compliance > Deposits > Brokered Deposits
Q:  Are insurance agents, lawyers, or accountants that refer clients to a bank considered to be deposit brokers?
 
A:    It depends.  The FDIC recognizes that within a community, there are many business professionals that conduct banking business with a particular insured financial institution, and due to that banking allegiance, often refer their customers to a particular financial institution on an informal basis for deposit products.  The deposits produced by those types of informal deposit referrals would generally not be considered brokered.  The deposits would be brokered, however, in more formal, programmatic arrangements between the insured depository institution and the business professionals, such as where (1) the professional has entered into a written agreement with the bank for the referral of depositors; or (2) the professional receives fees from the bank.  In these cases, the FDIC would generally consider the professional to have facilitated the placement of deposits in the bank, and therefore, the deposits received by the bank 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

Add Feedback