CDARS deposits are brokered deposits. Swept accounts are brokered deposits unless the bank receives a primary purpose exemption. Section 337.6 does not apply to well-capitalized institutions.
Is CDARS considered brokered deposits?
In conclusion, CDARS deposits should be excluded from the Notice's definition of brokered deposits. In fact, CDARS Reciprocal deposits should not be considered brokered deposits for any purpose.
What is considered brokered deposits?
The term "brokered deposit" means any deposit that is obtained from or through the mediation or assistance of a deposit broker. The term "deposit broker" refers to any person engaged in the business of placing deposits or facilitating the placement of deposits with insured depository institutions for a third party.