IPA Submits Comments on FDIC’s Proposed Brokered Deposits Rule

The Innovative Payments Association (IPA) has submitted a letter to the Federal Deposit Insurance Corporation (FDIC) addressing the proposed rule on recordkeeping for custodial accounts with transactional features. This rule is intended to enhance the FDIC’s ability to determine deposit insurance coverage quickly in the event of an institution's failure.

In our response, we acknowledged the importance of the proposed rule while urging the FDIC to refine its scope. Specifically, we recommended excluding products like gift cards, single-load payment devices, and similar offerings that do not function as substitutes for traditional deposit accounts. We also highlighted concerns about the potential compliance burden and suggested extending the implementation period from one to two years.

To learn more, download the comment letter.

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Download Comment Letter