Paving Deposits: FDIC Roads Reciprocal Funds to Housing Act Compliance
Published Date: 9/1/2026
Rule
Summary
The Federal Deposit Insurance Corporation (FDIC) is amending its brokered deposit regulations to conform with recent changes to section 29 of the Federal Deposit Insurance Act made by section 902 of the 21st Century ROAD to Housing Act related to reciprocal deposits, which took effect on July 11, 2026. The FDIC is also providing certain clarifications regarding the reciprocal deposit framework to facilitate and simplify compliance. The FDIC invites public comment on this interim final rule.
Analyzed Economic Effects
5 provisions identified: 5 benefits, 0 costs, 0 mixed.
Much Larger Reciprocal Deposit Cap
The rule revises the general cap for reciprocal deposits to a tiered formula: 50% of liabilities up to $1,000,000,000; 40% of liabilities over $1,000,000,000 up to $10,000,000,000; and 30% of liabilities over $10,000,000,000 up to $96,333,333,333. The maximum general cap under this formula is $30,000,000,000 for institutions with $96.33 billion or more in total liabilities. The FDIC will calculate the cap using Call Report data.
More Banks Can Qualify As Agent Institutions
The rule amends the agent institution definition so that, when most recently examined, an institution with a CAMELS composite rating of 1, 2, or 3 (instead of only 1 or 2) and that is well capitalized qualifies as an agent institution. This expands the set of institutions that may except reciprocal deposits from being treated as brokered deposits.
Estimated FDIC Assessment Revenue Drop
Based on March 31, 2026 data, the FDIC estimates aggregate assessment revenue could be reduced by about $45.8 million annually as a result of the changes that permit more reciprocal deposits to be excepted from brokered treatment.
Some Banks May See Lower FDIC Assessments
The FDIC estimates that, if reciprocal deposits are excepted from brokered treatment, 16 small FDIC-insured institutions could have lower assessments due to changes in the brokered deposit ratio; 14 large or highly complex institutions could have lower assessments due to changes in the core deposit ratio; and 3 institutions could have lower assessments due to changes in the brokered deposit adjustment.
Clarified When Reciprocal Deposits Are 'Received'
The FDIC clarifies that an agent institution only 'receives' nonmaturity reciprocal deposits for purposes of the special cap when it places a covered deposit through a deposit placement network. Changes in the identities or amounts attributable to individual depositors due to network rebalancing do not alone constitute 'receiving' additional reciprocal deposits if the aggregate amount held does not increase. An institution may continue to hold reciprocal deposits received prior to becoming subject to the special cap but will be disqualified if it places covered deposits causing holdings to exceed the special cap.
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