FDIC Issues Guidance Taking a Very Broad View of What Are Considered “Brokered Deposits”

The Federal Deposit Insurance Corporation ("FDIC") has issued guidance in the form of "Frequently Asked Questions" for identifying, accepting, and reporting brokered deposits (the "Guidance"). While the Guidance is not intended to change any existing requirements or impose any new requirements on banks, the Guidance makes clear that the FDIC takes a very broad view of what is considered a brokered deposit.