Reversing much in its 2020 brokered-deposit standards, the FDIC is proposing a new regime dictating how banks that are less than well-capitalized facing deposit shortfalls may raise funds from third parties, including even their own affiliates. Even well-capitalized IDIs would face significant strategic challenges because many funds now not considered brokered deposits would need to be recategorized as such, triggering costly requirements in current liquidity and FDIC premium-assessment regulation. Switching to alternative funding sources is likely to prove more costly and, where IDIs rely on swept funds from affiliates, a challenge to business models premised at least in part on broker-dealer and/or investment-adviser synergies.
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