THE BANKING LAW JOURNAL
CONCLUSION
The new Financial Institution Letter adds important clariï¬cations and
additional explanations to the FDIC’s January 2015 brokered deposits resources. The revised documents should help to provide clarity on when deposits
are considered brokered. This is especially important as the FDIC has made
clear that, despite criticism of its distinctions between core and brokered
deposits, the treatment of brokered deposits is unlikely to change in the near
future.
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