CMS Case Study

Brokered CDs When appropriate, the Bank may also utilize brokered CD's as an alternative source of funds for reasons outlined above. Since brokered CDs do not require collateral, they have the potential for being less reliable than other forms of wholesale funding and, therefore, must be managed accordingly. In conjunction with this policy, the Bank may solicit funds from qualified and Board approved brokerage firms. Financial background analysis and due diligence must be performed to qualify a broker before deposits are accepted by the Bank. Financial information on all brokers will be updated and reviewed annually. The ALCO is responsible for the administration of these guidelines within the context of the Bank's Asset/Liability and Funds Management Policy Statement. Brokered deposits are limited to 15% of the Bank’s total asset base. Board approval is required to exceed these limits.

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Approved by Board of Directors 1/20/22