If an insured institution ceases to be well capitalized, should existing non-brokered CDs that exceed the applicable rate caps be reported as brokered deposits in the Consolidated Reports of Condition and Income?

Compliance > Deposits > Brokered Deposits
Q:  If an insured institution ceases to be well capitalized, should existing non-brokered CDs that exceed the applicable rate caps be reported as brokered deposits in the Consolidated Reports of Condition and Income?
 
A:    No. Above-market CDs, generated before a bank falls below well capitalized, should not be reported as brokered deposits; they also may continue to be held until their maturity dates. At renewal, the certificate of deposit cannot exceed the applicable market average by more than 75 basis points.
 

This can be found in FDIC’s FAQs on Brokered Deposits, which can be found at https://www.fdic.gov/news/news/financial/2015/fil15002a.pdf

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