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FDIC Treatment of Reciprocal Deposits

I'm not sure if this is the appropriate comment to include a suggestion on the FDIC's "Non-Core Funding" ratio or not?  In my discussions with two different regulators regarding the new treatment of reciprocal deposits, both individuals were hesitant to say, one way or another, that reciprocal deposits would be excluded from the non-core funding ratio.  This means that the FDIC benchmark for monitoring liquidity will still treat these reciprocal deposits as "non-core". 

My hope that is in asking for further comment, they are addressing this particular issue as well.

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Cole Hewitt
CFO
Yampa Valley Bank
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Original Message:
Sent: 09-17-2018 10:39
From: Dawne Stafford
Subject: FDIC Treatment of Reciprocal Deposits

I received notice on Friday asking for comments regarding proposed rule change to implement Section 202 of the EGRRPA.  What is still under discussion? 

 

Dawne Stafford | President & CFO

Ph: (918) 664.6100 | Fax: (918) 664.8778

10727 East 51st Street | Tulsa, OK  74146 | PO Box 471316 | Tulsa, OK  74147-1316

Please note my new email address:  dstafford@sbtulsa.bank

 

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