REVERSEinquiries Workshop Series: Certificate of Deposit Programs and Brokered CD Programs

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.