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.