The FDIC has approved an Interim Final Rule both expanding the criteria for a bank that places deposits through a deposit placement network to be considered an agent institution and increasing the amount of reciprocal deposits that an agent institution can take without counting them as brokered deposits. Our client update summarizes key components of the rule, which became effective as of September 1, 2026.


This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm’s privacy notice for further details.