The proposal would make key changes to the definition of “deposit broker” with significant ramifications for banks, fintechs, bank-fintech partnerships, and other third parties in the financial services industry.

By Arthur S. Long, Parag Patel, Barrie VanBrackle, Pia Naib, and Deric Behar

The Board of Directors of the Federal Deposit Insurance Corporation (FDIC) recently approved a Notice of Proposed Rulemaking (“Unsafe and Unsound Banking Practices: Brokered Deposits Restrictions”) (the Proposal) to amend the agency’s brokered deposit