BAS Presentations - March 2023

3/1/2023

Falling Below Well Capitalized Impacts Liquidity

Deposit Rate caps (1) average national rate + 75bps, or (2) for maturity deposits 120% of current treasury yield on similar maturity, and non ‐ maturity at Fed Funds rate + 75bps

Brokered deposits restricted  Banks may not accept or renew brokered deposits – no waivers.

(Part 337.6 & 337.7 FDIC Rules and Regulations)

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“Reliance on non-core funding sources is a risky strategy. These funds may not be available in times of financial stress and can lead to liquidity shortfalls.”

Summary Analysis of Failed Banks Office of Inspector General, September 2011

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