On 12/29/2021, the FDIC issued an update on the Questions and Answers Related to Brokered Deposits Rule. In particular, one question was added under the Primary Purpose Exception section and two were added to the Reporting section of the FAQs.

The newly added FAQS answered questions on:

Circumstances where third parties can qualify for the exception for third-party administrators of health savings accounts;
Filing deadlines and penalties for quarterly updates under the 25 percent test;
Filing deadlines and penalties for the annual certification under the “enabling transaction” test.

See the full list of FAQs here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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