We will provide an overview of the documentation and other requirements to establish a certificate of deposit program or brokered certificate of deposit program. We will review the bank regulatory, distribution related, FINRA related, and suitability related considerations. Among other things, we will discuss:

  • Setting up a CD program;
  • Disclosure and documentation considerations;
  • Settlement issues;
  • The bank regulatory differences between CD and brokered CD issuances;
  • The FDIC advance notice of proposed rulemaking on brokered CDs; and
  • FINRA and securities law considerations.
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