Letter to the FDIC on the Interim Final Rule on Reciprocal Deposits

Dear Ms. Jones:

The American Bankers Association (ABA) appreciates the opportunity to comment on the Federal Deposit Insurance Corporation's (FDIC) interim final rule (IFR) amending its brokered deposit regulations to conform with the changes to section 29 of the Federal Deposit Insurance Act enacted through section 902 of the 21st Century ROAD to Housing Act.

ABA welcomes the FDIC's prompt implementation of section 902 of the 21st Century ROAD to Housing Act and strongly supports the IFR. In addition to aligning Part 337 with the statute, the IFR provides helpful clarifications that simplify compliance with the reciprocal deposit framework. Reciprocal deposits are an important source of stable, diversified funding for many ABA members, enabling these institutions to retain established customer relationships by providing depositors with expanded deposit insurance coverage through a single banking relationship. By helping banks compete for and retain deposits that might otherwise leave their communities, reciprocal deposits strengthen banks' capacity to meet local credit needs and support households, small businesses, and economic growth.

ABA hopes the FDIC's implementation of section 902 of the 21st Century ROAD to Housing Act will serve as a meaningful first step toward a broader reassessment of section 29.

If you have any questions, please contact me at [email protected]. ABA looks forward to continuing its engagement with the FDIC on these issues.

Sincerely,
Alison Touhey