C3 - When a bank only places deposits within a network of affiliated banks, is the bank acting as a deposit broker?

Compliance > Deposits > Brokered Deposits
Q:  When a bank only places deposits within a network of affiliated banks, is the bank acting as a deposit broker?
 
A:    Yes.  If a bank, or its parent company, places part or all of a depositor’s funds with affiliated banks, then it is acting as a deposit broker.  As a result, the deposits are brokered deposits.


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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