House members request reconsideration of FDIC brokered deposits interpretation
CFPB Monitor
AUGUST 1, 2018
By way of example, the 2016 FAQ states that deposits generated by “advertising or referrals by third parties (such as nonprofit affinity groups as well as commercial enterprises), in exchange for volume-based fees” would be deemed brokered deposits even if the customers themselves would subsequently become core customers of the institution.
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