Fall Regulatory Summit

Internal Use Only

CDARS and ICS Reciprocal (cont.)

ICS and CDARS Reciprocal Fees For banks that hold more than 5% of liabilities or more than $500 million in deposits received through CDARS reciprocal, CDARS One-Way Buy, ICS Reciprocal, ICS One-Way Buy, and IntraFi Sweep 1

12.5 bps (annualized)

15 bps (annualized)

Banks that do not meet the threshold described above

[1] Every Friday evening, IntraFi will measure each institution’s participation levels to determine the pricing rate effective as of the first business day of the following week. A bank will qualify for the 12.5 bps rate if it meets the 5%/$500 million threshold on any of the preceding four Friday measuring dates. Newly onboarded members will enjoy the 12.5 bps rate for the six months following onboarding, regardless of their participation level. Additionally, members that would have had their rate increase to 15 bps as a result of acquiring another institution will continue to enjoy the 12.5 bps rate for the six months after the effective date of the acquisition. After six months, the standard pricing requirements will apply to these members.

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Internal Use Only

Most Reciprocal Deposits Are Nonbrokered

ƒ In 2018, the Economic Growth, Regulatory Relief, and Consumer Protection Act was enacted. The law revised the FDI Act to make most reciprocal deposits reportable as nonbrokered. ƒ Under this law, for a well-capitalized bank with a CAMELS rating of 1 or 2, reciprocal deposits up to the lesser of $5 billion or 20% of the bank’s total liabilities are no longer considered brokered. (Reciprocal deposits over these amounts are treated as brokered.) ƒ A bank that drops below well-capitalized no longer requires a waiver from the FDIC to continue accepting reciprocal deposits up to the lesser of $5 billion or 20% of total liabilities, so long as the bank does not increase its overall reciprocal balance over the previous-four-quarters average from when it first became less than well-capitalized or dropped below a 1 or 2 CAMELS rating.

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