Product Updates September 2026
The Product Updates for September 2026 from BankPolicies.com feature the following revised policy template products:
Asset, Liability, and Liquidity Management Policy Template
Brokered Deposits Policy Template
The update to these products is in response to FDIC FIL-52-2026 entitled “Interim Final Rule on Reciprocal Deposits” dated 08/27/26 that announced an adoption of an interim final rule to implement section 902 of the 21st Century ROAD to Housing Act (the Housing Act), which amended the statutory framework governing reciprocal deposits, and to provide clarifications regarding the operation of the reciprocal deposits framework. In general, the interim final rule:
- Amends the FDIC’s brokered deposit regulations concerning the limited exception for reciprocal deposits to conform to section 29 of the Federal Deposit Insurance Act, as amended by section 902 of the Housing Act;
- Increases the amount of reciprocal deposits agent institutions may exclude from treatment as brokered deposits by modifying the “general cap” with a new tiered liability-based calculation, up to a maximum of $30 billion;
- Amends the definition of “agent institution” to include 3-rated, well capitalized institutions;
- Clarifies when an institution “receives” nonmaturity reciprocal deposits;
- Clarifies when an institution requalifies as an agent institution following a supervisory rating change, capital-category change, approval of a brokered deposits waiver, or a reduction in reciprocal deposits below its “special cap;” and
- Outlines coordination with the Federal Financial Institutions Examination Council (FFIEC) to update Call Report instructions.
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