FDICGuidancelow

Industry-Wide (All FDIC-Supervised Banks)

On December 15, 2020, the FDIC finalized its revised brokered deposits rule, which modernized the framework governing how deposits facilitated by third parties are classified. The rule specifically exempted single-bank fintech platforms, pass-through deposit facilitators, and lending-focused services from brokered deposit restrictions. This was widely viewed as a win for the bank-fintech partnership model, as it reduced regulatory burden on BaaS arrangements where fintechs channel deposits to a single partner bank. The rulemaking clarified longstanding ambiguity that had created compliance uncertainty for sponsor banks and their fintech partners.

Verified from source: The FDIC approved a new brokered deposits rule on December 15, 2020, that modernized brokered deposit definitions to support bank-fintech partnerships. The OCC's Acting Comptroller issued a statement supporting the rule, which excluded certain fintech-bank arrangements from brokered deposit restrictions.

Implications
  1. Reduced regulatory friction for BaaS deposit programs operating through a single sponsor bank
  2. Encouraged growth of fintech-bank deposit partnerships by removing brokered deposit classification risk
  3. Set a precedent for regulators taking a supportive rather than restrictive stance toward certain BaaS models
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