The FDIC’s 2026 interim final rule updates how eligible banks calculate the amount of reciprocal deposits they may exclude from brokered-deposit treatment and expands one route to agent-institution eligibility. The statutory changes took effect July 11, 2026. For banks, the practical changes are a three-tier liability-based cap and a revised rating test; Call Report implementation details should be checked against current FFIEC instructions.
What reciprocal deposits and the agent-institution exception do
Reciprocal deposit arrangements allow a bank to place customer deposits through a network and receive deposits back from other participating institutions. The statutory exception can allow qualifying reciprocal deposits to be excluded from brokered-deposit treatment, subject to eligibility requirements and a cap. The 2026 amendments revise that cap and one part of the test for qualifying as an agent institution.
The FDIC implemented the statutory changes through Part 337. Its notice describes the rule as an interim final rule and includes clarifications intended to simplify compliance. The Federal Register notice was published September 1, 2026, with comments due October 1, 2026; that deadline has passed.
How the new reciprocal-deposit cap is calculated
The general cap is calculated in tiers based on total liabilities. Each rate applies only to the liabilities within its tier, not to the institution’s entire liability figure. The maximum cap is $30 billion.
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| Total-liability portion | Rate applied | Maximum contribution to cap |
|---|---|---|
| First $1 billion | 50% | $500 million |
| Above $1 billion through $10 billion | 40% | $3.6 billion |
| Above $10 billion through $96.333 billion | 30% | $26 billion |
The FDIC’s example for an institution with $25 billion in total liabilities produces an $8.6 billion general cap: (50% × $1 billion) + (40% × $9 billion) + (30% × $15 billion). The FDIC says it will continue to calculate the cap using Call Report data. These are statutory thresholds and a regulator’s calculation example, not measured evidence of effects on bank funding or lending. FDIC information on brokered deposits provides the agency’s material on the subject.
How the formula differs from the earlier cap
Under the earlier framework, qualifying well-capitalized and well-rated institutions could exclude the lesser of 20% of total liabilities or $5 billion. The new tiered formula can provide a larger exclusion, up to $30 billion, if the institution meets the applicable eligibility requirements. The former limit is described in the FDIC’s 2018 rule. FDIC’s 2018 rule.
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Which institutions can qualify as agent institutions
The first statutory eligibility prong now accepts a CAMELS composite rating of 1, 2, or 3—or an equivalent rating under a comparable rating system—at the institution’s most recent examination. The institution must also be well capitalized. The other two statutory prongs remain unchanged, so meeting this rating test alone does not establish eligibility.
Because the exception depends on the full statutory criteria as well as the cap, an institution should evaluate all applicable prongs and its capital status before treating reciprocal deposits as exempt from brokered-deposit classification. The rule’s Part 337 amendments implement the statutory changes; they do not replace the remaining eligibility conditions.
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What banks should know about September 2026 Call Report timing
The law took effect July 11, 2026, before the September 30, 2026 Call Report date. The interim final rule said the FFIEC would issue supplemental instructions for that report so institutions could report brokered and reciprocal deposits consistently with the amended law. It anticipated conforming Call Report instructions by December 31, 2026.
- The rule said no new Call Report line items would be needed.
- It said the FDIC anticipated working through the FFIEC to make Schedule RC-O, item 9 (brokered reciprocal deposits) confidential.
- Those were forward-looking statements in the rule. Institutions preparing or correcting reports should consult current FFIEC instructions rather than rely on the anticipated schedule or confidentiality change alone.
What the ABA supports—and what the rule does not establish
The American Bankers Association welcomed the rule’s clarifications. The ABA describes reciprocal deposits as a stable, diversified funding source for many member banks and says they can help banks maintain customer relationships while providing depositors expanded deposit-insurance coverage through a single banking relationship. Those are the association’s stated views; the cited ABA coverage does not provide measured outcome data showing effects on deposit stability, lending, or local economies.
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The ABA also presents the rule as a possible first step toward broader reconsideration of Section 29 of the Federal Deposit Insurance Act, which governs brokered deposits. Its broader policy position is distinct from the specific statutory changes implemented in this rule. ABA Banking Journal’s report on the rule.
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