On December 15, 2020, the Federal Deposit Insurance Corporation (“FDIC”) finalized revisions to rules and prior guidance intended to modernize the FDIC’s framework for regulating brokered deposits. These revisions alter both the substantive regulations for brokered deposits and the procedures for requesting exceptions and filing reports, modify the restrictions on interest rates for certain types of deposits, and clarify the application of the brokered deposit requirements to non-maturity deposits. In this Legal Update, we discuss the background of the brokered deposit restrictions and describe the key elements of the revisions, which generally will become effective on April 1, 2021.

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