What are Brokered Deposits? A Comprehensive Guide for Financial Institutions

In today’s dynamic financial landscape, understanding the intricacies of brokered deposits is crucial for financial institutions. Brokered deposits, as the name suggests are deposits placed with banks or other insured depository institutions through the mediation of a third-party intermediary known as a deposit broker. These deposits can be a valuable source of funding for financial institutions but they also come with specific regulations and considerations.

This comprehensive guide delves into the world of brokered deposits, providing financial institutions with the knowledge and insights they need to navigate this complex financial instrument effectively.

Demystifying Brokered Deposits: Definitions and Key Players

What are Brokered Deposits?

A brokered deposit is any deposit obtained from or through the assistance of a deposit broker. Deposit brokers act as intermediaries, connecting investors with insured depository institutions seeking funding. These brokers typically work with a network of banks and credit unions, offering investors a wider range of options and facilitating the placement of deposits that meet their specific needs.

Who are Deposit Brokers?

Deposit brokers are individuals or entities engaged in the business of placing deposits or facilitating the placement of deposits with insured depository institutions for a third party. These brokers play a vital role in connecting investors with financial institutions, ensuring efficient capital allocation within the financial system.

Understanding the Regulatory Framework

The Federal Deposit Insurance Corporation (FDIC) plays a crucial role in regulating brokered deposits. Section 29 of the Federal Deposit Insurance Act (FDI Act) outlines the rules and restrictions governing these deposits.

  • Capitalization Requirements: Well-capitalized insured depository institutions can accept brokered deposits without restriction. Adequately capitalized institutions can apply for and be granted a waiver from the FDIC to accept brokered deposits. Undercapitalized institutions are prohibited from accepting brokered deposits.

  • Interest Rate Restrictions: Less than well-capitalized institutions cannot offer rates on brokered deposits that are significantly higher than prevailing market rates in their normal market area.

Types of Brokered Deposits

Brokered deposits can be categorized into three primary types:

  • Direct Certificates of Deposit (CDs): These CDs are issued directly by financial institutions to investors, with or without the involvement of a deposit broker.

  • CDs with Third-Party Administration: In these arrangements, a third party, such as Primary Financial, acts as an administrator, custodian, agent, or trustee for the CD. These deposits are generally considered brokered deposits.

  • DTC-Eligible Brokered Deposits: These deposits are held in the Depository Trust Company (DTC), a central securities depository, and are subject to specific eligibility criteria.

Accepting Brokered Deposits: Benefits and Considerations

For financial institutions, accepting brokered deposits offers several potential benefits:

  • Access to a Larger Market: Brokered deposits provide access to a wider pool of investors than relying solely on local market deposits.

  • Competitive Rates: Financial institutions can often secure deposits at lower rates through brokers compared to soliciting rates nationally through rate services.

  • Operational Efficiency: Working with a central contact point, such as a deposit broker, can streamline operations and reduce administrative costs.

  • Attracting Larger Deposits: Brokered deposits often represent larger sums, reducing the need to manage multiple smaller deposits.

However, financial institutions must also consider the following factors when accepting brokered deposits:

  • Regulatory Compliance: Ensuring compliance with FDIC regulations and adhering to sound risk management practices is essential.

  • Due Diligence: Carefully assessing the reputation and track record of deposit brokers and conducting thorough due diligence on individual deposits is crucial.

  • Portfolio Diversification: Diversifying the deposit portfolio across various sources and maturities helps mitigate risks associated with brokered deposits.

Navigating the Brokered Deposit Landscape: Resources and Support

Financial institutions have access to various resources and support to navigate the intricacies of brokered deposits.

  • FDIC Resources: The FDIC provides comprehensive information on brokered deposits through its website, including regulations, guidance, and FAQs.

  • Primary Financial: As a leading provider of brokered deposit services, Primary Financial offers financial institutions a wealth of resources, including market insights, regulatory updates, and educational materials.

  • Industry Associations: Trade associations such as the American Bankers Association and the Independent Community Bankers of America provide valuable resources and advocacy for financial institutions.

Brokered deposits can be a valuable funding source for financial institutions, offering access to a wider investor pool, competitive rates, and operational efficiencies. By understanding the regulatory framework, conducting thorough due diligence, and diversifying their deposit portfolio, financial institutions can leverage brokered deposits to enhance their funding strategies and achieve their financial goals.

What is a brokered deposit and who is a deposit broker?

Any deposit obtained from or with the help of a deposit broker is referred to as a “brokered deposit.”

Any individual who works in the business of making deposits for third parties or arranging for deposits to be made with insured depository institutions is referred to as a “deposit broker.”

To see the FDICs definitions of “brokered deposit”” and “deposit broker”, view C.F.R. 337.6 at the FDICs web site.

In actuality, there are three types of deposits that could be relevant:

  • direct investor certificates of deposit, which might or might not be brokered deposits;
  • certificates of deposit, which are typically regarded as brokered deposits and in which a third party, like Primary Financial, serves as an administrator, custodian, agent, or trustee; and
  • DTC-eligible brokered deposits.

Who can accept brokered deposits?

According to Part 337 of the FDIC Rules and Regulations, which implements Section 29 of the FDI Act, a well-capitalized, insured depository institution is free to solicit and accept, renew, or roll over any brokered deposit without any limitations. Once it has applied for and been granted a waiver by the FDIC, a sufficiently capitalized, insured depository institution may accept, renew, or roll over any brokered deposit. No brokered deposit may be accepted, renewed, or rolled over by an undercapitalized insured depository institution.

What are Brokered Deposits

FAQ

What is an example of a broker deposit?

Common examples of “brokered deposits” other than traditional brokered CDs include sweep accounts, deposits acquired through deposit networks, and numerous other accounts where the bank relies on an intermediary to acquire customers.

Are brokered deposits insured by FDIC?

Overview. Custodial deposits held in the name of a Broker on behalf of their investors and deposited in an FDIC insured financial institution are covered by federal deposit insurance, the same as if the funds had been deposited directly by the broker’s clients in the same institution.

Where do banks obtain brokered deposits?

Brokered deposits are what they sound like: A bank can go to a third-party broker such as Morgan Stanley or Fidelity to find customers to invest in the bank’s high-yielding certificates of deposit. That allows the bank to get big influxes of money at once, rather than customer by customer.

What is deposit brokering?

A deposit broker is an individual or firm that facilitates the placement of investors’ deposits with insured depository institutions. Deposit brokers offer investors an assortment of fixed-term investment products, many of which yield low-risk returns.

What is a broker deposit?

The term “brokered deposit” means any deposit that is obtained from or through the mediation or assistance of a deposit broker. The term “deposit broker” refers to any person engaged in the business of placing deposits or facilitating the placement of deposits with insured depository institutions for a third party.

What is a brokered Certificate of deposit?

A brokered certificate of deposit is like a standard CD that is offered by a brokerage instead of a bank. A CD, whether at a bank or brokerage, is a type of savings account that requires an upfront deposit for a fixed period at a fixed rate. Brokered CDs, specifically, are CDs provided through brokerages and issued by banks.

What are brokered deposits & core deposits?

Brokered deposits and core deposits are the two types of deposits that make up a bank’s deposit liabilities. Core deposits include checking accounts, savings accounts, and certificates of deposit held by individuals.

Can a bank take a brokered deposit?

Under Federal Deposit Insurance Corporation (FDIC) rules, only well-capitalized banks can solicit and accept brokered deposits. Adequately capitalized banks may take them after being granted a waiver, and under-capitalized banks cannot accept them at all. Even if a bank is well-capitalized, overuse of brokered deposits can lead to losses.

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