Consolidated Reports of Condition and Income

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FFIEC 031
Revisions to the FFIEC 031 Call Report Form and Instructions for
Interim Final Rule on Reciprocal Deposits 1

These proposed revisions, which are subject to change, implement
statutory amendments to section 29 of the Federal Deposit
Insurance Act concerning the treatment of reciprocal deposits.

The federal banking agencies have requested emergency approval
from the U.S. Office of Management and Budget under the
Paperwork Reduction Act for these revisions to the FFIEC 031 Call
Report form and instructions. Subject to OMB approval, the
revisions would take effect for the September 30, 2026, report date.

The agencies intend to follow the emergency-clearance request with
a request under the normal Paperwork Reduction Act clearance
procedures, including publication of notices providing the public
with an opportunity to comment.

On September 1, 2026, the FDIC published an interim final rule titled, “Reciprocal Deposits: Implementing
the 21st Century ROAD to Housing Act.”

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FFIEC 031
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RC-73

Optional Narrative Statement Concerning the Amounts
Reported in the Consolidated Reports of Condition and Income
750 characters, as defined, it will be truncated at 750 characters
with no notice to the submitting bank and the truncated statement
will appear as the bank’s statement both on agency computerized
records and in computer-file releases to the public.
items 9 and 9.a and

All information furnished by the bank in the narrative statement
must be accurate and not misleading. Appropriate efforts shall be
taken by the submitting bank to ensure the statement’s accuracy.
If, subsequent to the original submission, material changes are
submitted for the data reported in the Consolidated Reports of
Condition and Income, the existing narrative statement will be
deleted from the files, and from disclosure; the bank, at its option,
may replace it with a statement appropriate to the amended data.

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The management of the reporting bank may, if it wishes, submit a
brief narrative statement on the amounts reported in the
Consolidated Reports of Condition and Income. This optional
statement will be made available to the public, along with the
publicly available data in the Consolidated Reports of Condition
and Income, in response to any request for individual bank report
data. However, the information reported in Schedule RI-E, item
2.g; Schedule RC-C, Part I, Memorandum items 17.a and 17.b;
Schedule RC-O, Memorandum items 6 through 9, 14, 15, and 18;
and Schedule RC-P, items 7.a and 7.b, is regarded as
confidential and will not be made available to the public on an
individual institution basis. BANKS CHOOSING TO SUBMIT THE
NARRATIVE STATEMENT SHOULD ENSURE THAT THE
STATEMENT DOES NOT CONTAIN THE NAMES OR OTHER
IDENTIFICATIONS OF INDIVIDUAL BANK CUSTOMERS,
REFERENCES TO THE AMOUNTS REPORTED IN THE
CONFIDENTIAL ITEMS IDENTIFIED ABOVE, OR ANY OTHER
INFORMATION THAT THEY ARE NOT WILLING TO HAVE MADE
PUBLIC OR THAT WOULD COMPROMISE THE PRIVACY OF
THEIR CUSTOMERS. Banks choosing not to make a statement
may check the “No comment” box below and should make no
entries of any kind in the space provided for the narrative
statement; i.e., DO NOT enter in this space such phrases as “No
statement,” “Not applicable,” “N/A,” “No comment,” and “None.”

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The optional statement must be entered on this sheet. The statement should not exceed 100 words. Further, regardless of the
number of words, the statement must not exceed 750 characters,
including punctuation, indentation, and standard spacing
between words and sentences. If any submission should exceed

The optional narrative statement will appear in agency records
and in release to the public exactly as submitted (or amended as
described in the preceding paragraph) by the management of
the bank (except for the truncation of statements exceeding the
750-character limit described above). THE STATEMENT WILL
NOT BE EDITED OR SCREENED IN ANY WAY BY THE
SUPERVISORY AGENCIES FOR ACCURACY OR RELEVANCE.
DISCLOSURE OF THE STATEMENT SHALL NOT SIGNIFY
THAT ANY FEDERAL SUPERVISORY AGENCY HAS VERIFIED
OR CONFIRMED THE ACCURACY OF THE INFORMATION
CONTAINED THEREIN. A STATEMENT TO THIS EFFECT WILL
APPEAR ON ANY PUBLIC RELEASE OF THE OPTIONAL
STATEMENT SUBMITTED BY THE MANAGEMENT OF THE
REPORTING BANK.

RCON Yes

No

Comments? .................................................................................................................................. 6979

BANK MANAGEMENT STATEMENT (please type or print clearly; 750 character limit):

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(TEXT 6980)

06/2020
09/2026

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Memoranda
Item No.

Caption and Instructions
Selected components of total deposits. The amounts to be reported in Memorandum
items 1.a through 1.i below are included as components of total deposits (in domestic offices)
(Schedule RC-E, sum of item 7, columns A and C).

1.a

Total Individual Retirement Accounts (IRAs) and Keogh Plan accounts. Report in this
Memorandum item the total of all IRA and Keogh Plan deposits included in total deposits
(in domestic offices) (Schedule RC-E, sum of item 7, columns A and C). IRAs include
traditional IRAs, Roth IRAs, Simplified Employee Pension (SEP) IRAs, and SIMPLE IRAs.

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1

Exclude deposits in "Section 457" deferred compensation plans and self-directed defined
contribution plans, which are primarily 401(k) plan accounts. Also exclude deposits in Health
Savings Accounts, Medical Savings Accounts, and Coverdell Education Savings Accounts
(formerly known as Education IRAs).

1.b

Total brokered deposits. Report in this Memorandum item the total of all brokered deposits
included in total deposits (in domestic offices) (Schedule RC-E, sum of item 7, columns A
and C), regardless of size or type of deposit instrument. (See the Glossary entry for
"brokered deposits" for the definition of this term.)
Brokered deposits include “brokered reciprocal deposits.” As defined in Section 327.8(q) of
the FDIC’s regulations, “brokered reciprocal deposits” are “reciprocal deposits as defined in
[Section] 337.6(e)(2)(v) of the FDIC’s regulations that are not excepted from anthe
institution’s brokered deposits pursuant to Section 337.6(e)[Section] 337.6(e)” of the FDIC’s
regulations.
Limited Exception for Reciprocal Deposits

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Pursuant to Section 337.6(e) of the FDIC’s regulations,, and consistent with12 U.S.C. 1831f(i)
as amended by Section 202902 of the Economic Growth, Regulatory Relief, and Consumer
Protection21st Century ROAD to Housing Act,,, an “agent institution” can except reciprocal
deposits from being classified (and reported in this Memorandum item 1.b) as brokered
deposits up to its applicable statutory caps, described below.
Definitions that apply to the limited exception for reciprocal deposits:
“Agent institution” means an insured depository institution that places a covered deposit
through a deposit placement network at other insured depository institutions in amounts
that are less than or equal to the standard maximum deposit insurance amount,
specifying the interest rate to be paid for such amounts, if the insured depository
institution:
o When most recently examined under section 10(d) of the Federal Deposit Insurance
Act (12 U.S.C. 1820(d)) was found to have a composite condition of outstanding or
good,assigned a composite CAMELS rating of 1, 2, or 3 under the Uniform Financial
Institutions Rating System (or an equivalent rating under a comparable rating
system); and is well capitalized;
o Has obtained a waiver pursuant to Section 337.6(c) of the FDIC’s regulations; or
o Does not receive an amount of reciprocal deposits that causes the total amount of
reciprocal deposits held by the agent institution to be greater than its special cap,
described below.
“Covered deposit” means a deposit that (i) is submitted for placement through a deposit
placement network by the agent institution; and (ii) does not consist of funds that were
obtained for the agent institution, directly or indirectly, by or through a deposit broker

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•

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Memoranda
Item No.

Caption and Instructions

1.b
(cont.)

•
•

“Network member bank” means an insured depository institution that is a member of a
deposit placement network.
“Reciprocal deposits” means deposits received by an agent institution through a deposit
placement network with the same maturity (if any) and in the same aggregate amount as
covered deposits placed by the agent institution in other network member banks.

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All reciprocal deposits, whether they are brokered reciprocal deposits or not, should be
reported in Schedule RC-E, Memorandum item 1.g, below.

Deposits placed and received through a “deposit placement network” that are not “covered
deposits” under Section 337.6(b)(2)(ii)(e)(2)(ii) of the FDIC’s regulations must be reported as
brokered deposits in this Memorandum item 1.b.
General Cap

Under the general cap, an agent institution may except reciprocal deposits from treatment as
brokered deposits up to the lessersum of $5 billion or an amount equal to 20:
50 percent of the agent institution’sportion of the total liabilities. of the agent
institution that is less than or equal to $1 billion;
40 percent of the portion, if any, of the total liabilities of the agent institution
that is greater than $1 billion, but less than or equal to $10 billion; and

30 percent of the portion, if any, of the total liabilities of the agent institution
that is greater than $10 billion, but less than or equal to $ $96,333,333,333.
.

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An agent institution that holds reciprocal deposits in excess of the general cap should report
such excess deposits as brokered deposits in this Memorandum item 1.b (and as brokered
reciprocal deposits in Schedule RC-O, item 9, and, if applicable, item 9.a), and include such
excess deposits as part of its total reciprocal deposits in Schedule RC-E, Memorandum item
1.g,.
In no event, however, can an institution’s non-brokered reciprocal deposits exceed the
general cap.
Special Cap

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A special cap applies if the institution is either not well ratedhas been assigned a CAMELS
rating of “4” or “5,” or is not well capitalized.1 The special cap is defined as:
“the average amount of reciprocal deposits held by the agent institution on the last day of
each of the 4 calendar quarters preceding the calendar quarter in which the agent
institution was found not to have a composite condition of outstanding or good or was
determined to be not well capitalized.”
In no event, however, can an institution’s non-brokered reciprocal deposits exceed the
general cap.
An institution that is not well ratedhas been assigned a CAMELS rating of “4” or “5,” or is not
well capitalized may qualify as an “agent institution” if:

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(1) The amount of reciprocal deposits that the institution holds as of the first reporting period
of being subject to the special cap is below or equal to the special cap and, in any
reporting period that it remains subject to the special cap, it does not subsequently
receive reciprocal deposits that cause the total amount of reciprocal deposits to exceed
the special capis below or equal to the special cap as of the quarter-end date of the Call
Report for which the institution is filing; OR
(2) The amount of reciprocal deposits that it holds as of the first quarter of being subject to
the special cap is above the special cap, if such deposits were received before the
institution became subject to the special cap and, in any reporting period that it remains ,
and it does not subsequently place a covered deposit through a deposit placement
network that causes its total amount of

1 See generally, 12 CFR Part 324, Subpart H (FDIC); 12 CFR Part 208, Subpart D (Federal Reserve Board); 12 CFR

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Part 6 (OCC). 12 U.S.C. 1831o. ‘‘Well capitalized’’ is defined in 12 CFR 337.6(a)(3)(i).

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Memoranda
Item No.

Caption and Instructions

1.b
(cont.)

subject to the special cap, it does not subsequently receive reciprocal deposits that cause
the total amount of reciprocal deposits to exceed the special cap and the institution
satisfies all other qualifications necessary to be an agent institution.

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(cont.)
If an institution, subject to the special cap, receives reciprocal deposits that cause its total
reciprocal deposits to be greater than the special cap, the institution will no longer meet the
definition of “agent institution” and all of its reciprocal deposits should be reported as
brokered deposits in this Memorandum item 1.b (and as brokered reciprocal deposits in
Schedule RC-O, item 9, and, if applicable, item 9.a) and as total reciprocal deposits in
Schedule RC-E, Memorandum item 1.g.

An institution shall consider the effective date of a CAMELS composite rating to be the
date of written notification to the institution by its primary federal regulator, or state authority,
of its supervisory rating.

An institution that is not well capitalized or that has a composite supervisoryCAMELS
rating of other than outstanding (CAMELS “1”)“4” or good (CAMELS “2”)“5” as of the quarterend date of the Call Report for which the institution is filing shall calculate the special cap by:
(1) Determining the most recent calendar quarter in which the institution was both well
capitalized and had a composite CAMELS rating of “1” or “2” at quarter-end.
(2) Calculating the average of the total amount of reciprocal deposits held by the institution
on the last day of the calendar quarter determined above (in the preceding step) and on
each of the three preceding calendar quarters.
To illustrate how an institution should calculate the special cap, consider the examples after
the instructions to Schedule RC-E, Memorandum item 7.

Brokered deposits of $250,000 or less (fully insured brokered deposits). Report in this
item all fully insured brokered deposits (as defined in the Glossary entry for "brokered
deposits") included in Schedule RC-E, Memorandum item 1.b, above. Include brokered
deposits with balances of $250,000 or less and time deposits issued to deposit brokers in the
form of certificates of deposit of more than $250,000 that have been participated out by the
broker in shares with balances of $250,000 or less.

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1.c

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In some cases, brokered certificates of deposit are issued in $1,000 amounts under a master
certificate of deposit issued by a bank to a deposit broker in an amount that exceeds
$250,000. For these so-called “retail brokered deposits,” multiple purchases by individual
depositors from an individual bank normally do not exceed the applicable deposit insurance
limit (currently $250,000), but under current deposit insurance rules the deposit broker is not
required to provide information routinely on these purchasers and their account ownership
capacity to the bank issuing the deposits. If this information is not readily available to the
issuing bank, these brokered certificates of deposit in $1,000 amounts may be rebuttably
presumed to be fully insured brokered deposits and should be reported in this item. In
addition, some brokered deposits are transaction accounts or money market deposit accounts
(MMDAs) that are denominated in amounts of $0.01 and established and maintained by the
deposit broker (or its agent) as agent, custodian, or other fiduciary for the broker’s customers.
An individual depositor’s deposits within the brokered transaction account or MMDA normally
do not exceed the applicable deposit insurance limit. As with retail brokered deposits, if
information on these depositors and their account ownership capacity is not readily available
to the bank establishing the transaction account or MMDA, the amounts in the transaction

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Memoranda
Item No.

Caption and Instructions

1.g
(cont.)

In this regard, if an institution, subject to the special cap, receives reciprocal deposits that
cause its total reciprocal deposits to be greater than the special cap, the institution will no
longer meet the definition of “agent institution,” but the institution should report all of its
reciprocal deposits in this Memorandum item 1.g (and as brokered deposits in
Schedule RC-E, Memorandum item 1.b, and as brokered reciprocal deposits in
Schedule RC-O, item 9, and, if applicable, item 9.a). See the instructions for Schedule RC-E,
Memorandum item 1.b, for the definitions of “special cap” and “agent institution.”

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Funds obtained through a deposit placement network,or with the assistance of a deposit
broker that are not reciprocal deposits should only be reported as brokered deposits in
Schedule RC-E, Memorandum item 1.b, and, if applicable, in Memorandum items 1.c and
1.d, and should not be reported in this Memorandum item 1.g as total reciprocal deposits.

For an institution that has been assigned a CAMELS rating of “4” or “5,” or is not well
capitalized or not well rated, the amount reported in this Memorandum item will be used to
compute the institution’s average amount of reciprocal deposits held at quarter-end during
the last four quarters preceding the calendar quarter thatin which the agent institution fell
belowwas found not to have a composite condition of outstanding or good or was determined
to be not well capitalized or well rated. . This average will be used to determine whether the
institution meets the third prong of the definition of “agent institution” under Section 202 of the
Economic Growth, Regulatory Relief, and Consumer Protection Act29 of the Federal Deposit
Insurance Act, as amended by Section 902 of the 21st Century ROAD to Housing Act, and
Section 337.6(e)(2)(i) of the FDIC’s regulations. Section 20229 and Section 337.6(e)(2)(i)
allow an institution to meet the “agent institution” definition, and exclude certain reciprocal
deposits from its brokered deposits, if it does not receive reciprocal deposits that cause its
total reciprocal deposits to exceed the four-quarter average mentioned above.

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NOTE: On the FFIEC 031 report form, Memorandum items 1.h.(1)(a), 1.h.(2)(a), 1.h.(3)(a), and 1.h.(4)(a)
are to be completed by institutions with $100 billion or more in total assets. Memorandum items
1.h.(1)(a), 1.h.(2)(a), 1.h.(3)(a), and 1.h.(4)(a) are not applicable to banks filing the FFIEC 041 report
form.
Sweep deposits. Report in appropriate subitem the indicated sweep deposit data (as
defined in the Glossary entry for “sweep deposits”).

1.h.(1)

Fully insured, affiliate sweep deposits. Report the amount of affiliate sweep deposits
that are fully insured.

1.h.(1)(a)

Fully insured, affiliate, retail sweep deposits. Report the amount of affiliate, retail
sweep deposits that are fully insured included in Memorandum item 1.h.(1) above.

1.h.(2)

Not fully insured, affiliate sweep deposits. Report the amount of affiliate sweep
deposits for which less than the entire amount of the deposits is covered by deposit
insurance.

1.h.(2)(a)

Not fully insured, affiliate, retail sweep deposits. Report the amount of affiliate, retail
sweep deposits for which less than the entire amount of the deposits is covered by
deposit insurance included in Memorandum item 1.h.(2) above.

1.h.(3)

Fully insured, non-affiliate sweep deposits. Report the amount of non-affiliate sweep

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1.h

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Memoranda
Caption and Instructions

7.a.(2)

Deposits in all other MMDAs of individuals, partnerships, and corporations. Report the
amount of all other MMDA deposits of individuals, partnerships, and corporations included in
Schedule RC-E, item 1, column C, that were not reported in Memorandum item 7.a.(1).

7.b

Other savings deposit accounts of individuals, partnerships, and corporations. Report
in the appropriate subitem the specified component of other savings deposits of individuals,
partnerships, and corporations reported in Schedule RC-E, item 1, column C, above. The
sum of Memorandum items 7.b.(1) and 7.b.(2) must be less than or equal to
Schedule RC-E, Memorandum item 2.a.(2), above.

7.b.(1)

7.b.(2)

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Item No.

Total deposits in those other savings deposit account deposit products intended
primarily for individuals for personal, household, or family use. Report the amount of
deposits reported in Schedule RC-E, item 1, column C, held in other savings deposit
accounts intended, marketed, or presented to the public primarily for individuals for personal,
household, or family use. Exclude other savings deposit accounts in the form of pooled funds
and commercial products with sub-account structures, such as escrow accounts, that are
held for individuals but not eligible for consumer transacting, saving, or investing.
Deposits in all other savings deposit accounts of individuals, partnerships, and
corporations. Report the amount of all other savings deposits of individuals, partnerships,
and corporations included in Schedule RC-E, item 1, column C, that were not reported in
Memorandum item 7.b.(1).

Examples – Calculating the Special Cap
(Note: Amounts shown are in thousands of dollars.)

Example 1 – Well capitalized but not well ratedassigned “4” or “5” rating

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As of March 31, 20192028, an institution has $9,000,00025 billion in total liabilities and $180,0006 billion
in total reciprocal deposits, is well capitalized (and has been well capitalized in every quarter for 10
years), but has a composite supervisory rating of “34”. Therefore, the institution is subject to the special
cap.

(1) Determine the most recent calendar quarter in which the institution was both well capitalized and
had a composite CAMELS rating of “1” or “2” at quarter-end.

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The effective date of the composite CAMELS rating of not “1” or “2“4” was March 15, 20182027,
the day the institution was notified in writing of a downgrade from CAMELS “2” to CAMELS “34”.
Thus, December 31, 20172026, represents the most recent quarter-end that the bank was rated
CAMELS “1” or “2” and was well capitalized.

(2) Calculate the average of the total amount of reciprocal deposits held by the institution on the last
day of the calendar quarter determined above (in the preceding bullet) and on each of the three
preceding calendar quarters.
To calculate the special cap, the institution must calculate the average amount of total reciprocal
deposits that it held as of the end of the four quarters ending December 31, 20172026,
September 30, 20172026, June 30, 20172026, and March 31, 20172026. In this example, the
institution received reciprocal deposits as follows for the last quarter in which it was well
capitalized and had a composite CAMELS rating of “1” or “2”,” and for the three prior quarters:

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Examples – Calculating the Special Cap (cont.)
•
•
•
•
•

December 31, 2017
September 30, 2017
June 30, 2017
March 31, 2017
Average for the four quarters

= $180,0002026
= $300,0002026
= $300,0002026
= $350,0002026
= $282,5007 billion

= $8 billion
= $7 billion
= $7 billion
= $6 billion

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The special cap would be $282,5007 billion and the general cap would be equal to (0.5 × $1,800,000 (the
lesser of $5,000,000 or billion) + (0.4 × $9,000,000 multiplied by 20 percent). billion) + (0.3 × $15 billion)
= $8.6 billion.
In this example, assuming that the institution satisfies all other qualifications necessary to be an agent
institution, the institution would meet the definition of an “agent institution.”

For its March 31, 20192028 Call Report, the institution would report $180,0006 billion in total reciprocal
deposits in Schedule RC-E, Memorandum item 1.g. Because the institution holds total reciprocal
deposits that are below its special cap, it would not have to report any reciprocal deposits as brokered
reciprocal deposits in Schedule RC-O, items 9 and 9.a, and would not have to include the reciprocal
deposits in its brokered deposits in Schedule RC-E, Memorandum items 1.b, 1.c, and 1.d.

If the institution receives reciprocal deposits that cause its total reciprocal deposits to be greater than
$282,5007 billion, it would no longer meet the definition of “agent institution” and all of the institution’s
reciprocal deposits would need to be reported as brokered reciprocal deposits in Schedule RC-O, item 9
(and, if applicable, item 9.a), and as total reciprocal deposits in Schedule RC-E, Memorandum item 1.g,
and they also would need to be included as part of the institution’s brokered deposits in Schedule RC-E,
Memorandum item 1.b (and, if applicable, in Memorandum items 1.c, and 1.d).
Example 2 – Well ratedAssigned rating of “1,” “2,” or “3” but not well capitalized

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As of March 31, 20192028, an institution has $5,000,00010 billion in total liabilities and $80,000150
million in total reciprocal deposits, has a composite CAMELS rating of “2” (and has been “2”-rated in
every quarter for 5 years), but is not well capitalized, and has not received a waiver to accept brokered
deposits. Therefore, the institution is subject to the special cap.

(1) Determine the most recent calendar quarter in which the institution was both well capitalized and
had a composite CAMELS rating of “1” or “2” at quarter-end.
The bank was last well capitalized as of its September 30, 2017,2027 Call Report. Thus,
September 30, 20172027, represents the most recent quarter-end that the bank was well
capitalized and rated CAMELS “1” or “2”.

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(2) Calculate the average of the total amount of reciprocal deposits held by the institution on the last
day of the calendar quarter determined above (in the preceding bullet) and on each of the three
preceding calendar quarters.
To calculate the special cap, the institution must calculate the average amount of total reciprocal
deposits that it held as of the end of the four quarters ending September 30, 20172027, June 30,
20172027, March 31, 20172027, and December 31, 20162026. In the example, the institution
held reciprocal deposits as follows for the last quarter in which it was well-capitalized and had a
composite CAMELS rating of “1” or “2”,,” and for the three prior quarters:
•
•
•
•

September 30, 2017
June 30, 2017
March 31, 2017
December 31, 2016

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= $100,0002027
= $150,0002027
= $100,0002027
= $02026
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= $200 million
= $200 million
= $300 million
= $100 million
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Average for the four quarters

= $87,500200 million

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Examples – Calculating the Special Cap (cont.)
The special cap would be $87,500200 million and the general cap would be equal to (0.5 × $1,000,000
(the lesser of $5,000,000 or $5,000,000 multiplied by 20 percent). billion) + (0.4 × $9 billion) = $4.1
billion.
In this example, assuming that the institution satisfies all other qualifications necessary to be an agent
institution, the institution would meet the definition of an “agent institution.”

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For its March 31, 20192028 Call Report, the institution would report $80,000150 million in total reciprocal
deposits in Schedule RC-E, Memorandum item 1.g. Because the institution holds total reciprocal
deposits that are below its special cap, it would not have to report any reciprocal deposits as brokered
reciprocal deposits in Schedule RC-O, items 9 and 9.a, and would not have to include the reciprocal
deposits in its brokered deposits in Schedule RC-E, Memorandum items 1.b, 1.c, and 1.d.

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The institution may not receive reciprocal deposits that cause its total reciprocal deposits to be greater
than $87,500200 million. Doing so would prevent the institution from meeting the definition of “agent
institution” and, as a consequence, all of its reciprocal deposits then would need to be reported as
brokered reciprocal deposits in Schedule RC-O, item 9 (and, if applicable, item 9.a), and as total
reciprocal deposits in Schedule RC-E, Memorandum item 1.g, and they also would need to be included
as part of its brokered deposits in Schedule RC-E, Memorandum item 1.b (and, if applicable, in
Memorandum items 1.c and 1.d).1

1

Under Section 29 of the Federal Deposit Insurance Act, an insured depository institution that is less than well
capitalized is restricted from accepting deposits by or through a deposit broker. The FDIC may waive this restriction if
the insured depository institution is adequately capitalized; however, the restriction cannot be waived if the institution
is undercapitalized.
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Item No.

Caption and Instructions

8.c

Over three years through five years. Report on an unconsolidated single FDIC certificate
number basis all subordinated notes and debentures with a remaining maturity of over three
years through five years.

8.d

Over five years. Report on an unconsolidated single FDIC certificate number basis all
subordinated notes and debentures with a remaining maturity of over five years.
NOTE: Amounts reported in items 9 and 9.a will not be made available to the public on an
individual institution basis.
Brokered reciprocal deposits. Report on an unconsolidated single FDIC certificate number
basis the amount of brokered reciprocal deposits included in the amount of brokered deposits
reported in Schedule RC-E, Memorandum item 1.b, “Total brokered deposits.” Exclude
reciprocal deposits that are not brokered reciprocal deposits. The amount reported in this
item for brokered reciprocal deposits should be less than or equal to Schedule RC-E,
Memorandum item 1.g, “Total reciprocal deposits.”

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9

As defined in Section 327.8(q) of the FDIC’s regulations, “brokered reciprocal deposits” are
“reciprocal deposits as defined in Section 337.6(e)(2)(v) of the FDIC’s regulations that are not
excepted from the institution’s brokered deposits pursuant to Section 337.6(e)” of the FDIC’s
regulations.
As defined in Section 337.6(e)(2)(v) of the FDIC’s regulations, “reciprocal deposits” means
“deposits received by an agent institution through a deposit placement network with the same
maturity (if any) and in the same aggregate amount as covered deposits placed by the agent
institution in other network member banks.” All reciprocal deposits, whether they are
brokered reciprocal deposits or not, should be reported in Schedule RC-E, Memorandum
item 1.g. The definitions of the terms “covered deposit,” “deposit placement network,” and
“network member bank” are included in the instructions for Schedule RC-E, Memorandum
item 1.g.

R

Limited Exception for Reciprocal Deposits

An “agent institution,” as defined in Section 337.6(b)(2)(ii)(e)(1) of FDIC regulations, and 12
U.S.C. 1831f(i), as amended by Section 902 of the 21st Century ROAD to Housing Act, can
except reciprocal deposits from being classified (and reported in Schedule RC-E,
Memorandum item 1.b) as brokered deposits up to its applicable statutory caps, described
below.

D

Under the general cap, an agent institution may except reciprocal deposits from treatment as
brokered deposits up to the lessersum of $5 billion or an amount equal to 20:
50 percent of the agent institution’sportion of the total liabilities. of the agent institution
that is less than or equal to $1 billion;
40 percent of the portion, if any, of the total liabilities of the agent institution that is greater
than $1 billion, but less than or equal to $10 billion; and
30 percent of the portion, if any, of the total liabilities of the agent institution that is greater
than $10 billion, but less than or equal to $96,333,333,333.

Reciprocal deposits in excess of the general cap, as well as those reciprocal deposits that
do not meet the definition of “covered deposit” under Section 337.6(b)(2)(ii)(e)(2)(ii) of the
FDIC’s regulations, are brokered deposits and must be reported in Schedule RC-E,
Memorandum item 1.b.
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RC-O - ASSESSMENTS

Definition of Special Cap ‒ A special cap applies if the institution is either not well rated or
has been assigned a composite CAMELS rating of “4” or “5,” or is not well capitalized.1 The
special cap is defined as:
“the average amount of reciprocal deposits held by the agent institution on the last day of
each of the 4 calendar quarters preceding the calendar quarter in which the agent
institution was found not to have a composite condition of outstanding or good or was
determined to be not well capitalized.”

AF
T

In no event, however, can an institution’s non-brokered reciprocal deposits exceed the
general cap.
1 See generally, 12 CFR Part 324, Subpart H (FDIC); 12 CFR Part 208, Subpart D (Federal Reserve Board); 12 CFR

D

R

Part 6 (OCC). 12 U.S.C. 1831o. ‘‘Well capitalized’’ is defined in 12 CFR 337.6(a)(3)(i).

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Item No.
9
(cont.)

RC-O - ASSESSMENTS

Caption and Instructions
Agent Institution ‒ An institution that is not well ratedhas been assigned a composite
CAMELS rating of “”4” or “”5” or is not well capitalized may qualify as an
“agent institution” if:

AF
T

(1) The amount of reciprocal deposits that the institution holds as of the first reporting period
of being subject to the special cap is below or equal to the special cap and, in any
reporting period that it remains subject to the special cap, it does not subsequently
receive reciprocal deposits that cause the total amount of reciprocal deposits to exceed
the special capis below or equal to the special cap as of the quarter-end datea of the Call
Report for which the institution is filing; OR
(2) The amount of reciprocal deposits that it holds as of the first quarter of being subject to
the special cap is above the special cap, if such deposits were received before the
institution became subject to the special cap, and, in any reporting period that it remains
subject to the special cap, it does not subsequently receive reciprocal deposits that cause
theplace a covered deposit through a deposit placement network that causes its total
amount of reciprocal deposits to exceed the special cap and the institution satisfies all
other qualifications necessary to be an agent institution..
If an institution, subject to the special cap, receives reciprocal deposits that cause its total
reciprocal deposits to be greater than the special cap, the institution will no longer meet the
definition of “agent institution” and all of its reciprocal deposits should be reported as
brokered deposits in Schedule RC-E, Memorandum item 1.b, and as brokered reciprocal
deposits in this item 9, and, if applicable, in item 9.a, below.

An institution shall consider the effective date of a CAMELS composite rating to be the date
of written notification to the institution by its primary federal regulator, or state authority, of its
supervisory rating.

R

An institution that is not well capitalized or that has been assigned a composite
supervisoryCAMELS rating of other than outstanding (CAMELS “1”)“4” or good (CAMELS
“2”)“5” as of the quarter-end date of the Call Report for which the institution is filing shall
calculate the special cap by:

(1) Determining the most recent calendar quarter in which the institution was both well
capitalized and had a composite CAMELS rating of “1” or “2” at quarter-end.
(2) Calculating the average of the total amount of reciprocal deposits held by the institution
on the last day of the calendar quarter determined above (in the preceding step) and on
each of the three preceding calendar quarters.

D

To illustrate how an institution should calculate the special cap, consider the examples after
the instructions to Schedule RC-E, Memorandum item 7.

NOTE: Item 9.a is to be completed on a fully consolidated basis by institutions that own another insured
depository institution.
9.a

Fully consolidated brokered reciprocal deposits. Report on a fully consolidated basis
the amount of brokered reciprocal deposits (as defined in Schedule RC-O, item 9, above)
included in the amount of brokered deposits reported in Schedule RC-E, Memorandum
item 1.b, “Total brokered deposits.”

10

Banker’s bank certification: Does the reporting institution meet both the statutory
definition of a banker’s bank and the business conduct test set forth in FDIC
regulations? If the reporting institution meets both of these criteria on an unconsolidated
single FDIC certificate number basis, it is a qualifying banker’s bank and should answer
“Yes” to item 10 and complete items 10.a and 10.b. If the reporting institution does not meet

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GLOSSARY

AF
T

Brokered Deposits (cont.):
Unless the custodian meets one of the specific exceptions from the “deposit broker” definition in
Section 29 of the Federal Deposit Insurance Act and Section 337.6(a) of the FDIC’s regulations, these
custodial accounts should be reported as brokered deposits in Schedule RC-E, Deposit Liabilities.
Section 202 of the Economic Growth, Regulatory Relief, and Consumer Protection Act, enacted on
May 24, 2018, amends
Section 29 of the Federal Deposit Insurance Act to exceptpermits a
capped amount of reciprocal deposits to be excepted from treatment as, and from being reported as,
brokered deposits for qualifying institutions. The FDIC has amended its regulations to conform to the
treatment of reciprocal deposits set forth in Section 202. As defined in Section 337.6(e)(2)(v) of the
FDIC’s regulations, “reciprocal deposits” means “deposits received by an agent institution through a
deposit placement network with the same maturity (if any) and in the same aggregate amount as
covered deposits placed by the agent institution in other network member banks.” As defined in
Section 327.8(q) of the FDIC’s regulations, “brokered reciprocal deposits” are “reciprocal deposits as
defined in Section 337.6(e)(2)(v) of the FDIC’s regulations that are not excepted from anthe institution’s
brokered deposits pursuant to Section 337.6(e)” of the FDIC’s regulations. Brokered reciprocal
deposits should be reported as (1) brokered deposits and included in Schedule RC-E, Memorandum
item 1.b, and, if applicable, Memorandum items 1.c and 1.d, and (2) brokered reciprocal deposits and
included in Schedule RC-O, item 9 and, if applicable, item 9.a. An institution should report its total
reciprocal deposits, including any reciprocal deposits that are reported as brokered deposits, in
Schedule RC-E, Memorandum item 1.g. For further information on reciprocal deposits and brokered
reciprocal deposits, see the instructions for Schedule RC-E, Memorandum items 1.b and 1.g, and the
examples after the instructions for Schedule RC-E, Memorandum item 7.
Fully insured brokered deposits are brokered deposits (including brokered deposits that represent
retirement deposit accounts as defined in Schedule RC-O, Memorandum item 1) with balances of
$250,000 or less or with balances of more than $250,000 that have been participated out by the
deposit broker in shares of $250,000 or less. As more fully described in the instructions for
Schedule RC-E, (Part I on the FFIEC 031), Memorandum item 1.c, fully insured brokered deposits also
include (a) certain brokered certificates of deposit issued in $1,000 amounts under a master certificate
of deposit issued by a bank to a deposit broker in an amount that exceeds $250,000 and (b) certain
brokered transaction accounts and money market deposit accounts denominated in amounts of $0.01
and established and maintained by the deposit broker (or its agent) as agent, custodian, or other
fiduciary for the broker’s customers.

D

R

For additional information on brokered deposits, refer to the FDIC’s Banker Resource Center Brokered
Deposit page at https://www.fdic.gov/banker-resource-center/brokered-deposits.

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GLOSSARY