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

Summary of FDIC ANPR

Requested feedback on: • Regulatory Treatment of Brokered Deposits • Deposit Interest Rate Caps • The FDIC asked 15 questions on these topics The ANPR provided background on: • FDIC Analysis shows brokered deposits can be a precursor for failure • Rate cap methodology change after the crisis. • Change to reciprocals

49

Past CSBS Policy

2009 Letter to FDIC - CSBS urged the FDIC to allow gradual decline of brokered deposits to prevent liquidity crisis for banks that become less than well-capitalized. CSBS suggested further analysis should be performed on how banks utilize brokered and specifically risky activity. 2011 Letter to FDIC - A CSBS comment letter to the FDIC suggested a reassessment of the definition of core deposits and a better approach to evaluating brokered deposits.

50