Q: When companies facilitate the placement of deposits through a bank network, are they acting as deposit brokers?
A: Yes. In sponsoring or operating a bank network, the company is facilitating the placement of deposits. Moreover, in acting as agents for customers in placing the customers’ funds at other insured depository institutions, the banks themselves are placing deposits and thus serving as deposit brokers. The involvement of deposit brokers in these networks means that the deposits are brokered deposits.