Bank Directors Seminar, Coeur d'Alene, ID, September 15-17, 2019

Current CSBS Policy Development Initiatives

Discussion Topics • Enhancing communication and transparency between FIs, regulators, law enforcement, and FinCEN

• Examination and enforcement approaches • BSA examiner resources and training needs • Beneficial Ownership .

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Brokered Deposits

• Adequately capitalized institutions can apply for a waiver from the FDIC. • Less than well capitalized institutions are constricted by the national rate-cap. • The rate cap is determined by adding 75 basis points to the national rate. • National rates are calculated based on a simple average of rates paid (annual percentage yield)

• Congress first gave the FDIC authority to restrict the use of brokered deposits in 1989 and tightened these standards further in the Federal Deposit Insurance Corporation Improvement Act of 1991. • Only Institutions considered well capitalized under the PCA can “solicit, accept or renew brokered deposits without any restrictions”.

by all insured depository institutions and branches for which data are available.

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