HIGH · Liquidity
Procedure L-02
Brokered deposit concentration elevated
Citation
12 CFR § 337.6 — Brokered deposits; FDIC Brokered Deposit Rule
Evidence
Brokered deposits $30,458M against total deposits $99,525M. Elevated brokered-deposit reliance can increase liquidity sensitivity, funding-cost volatility, and supervisory restrictions if capital condition weakens.
Recommended action
Provide a brokered-deposit funding plan with board-approved concentration limits, maturity distribution, rate-sensitivity analysis, and contingency actions if brokered channels become unavailable or restricted. Demonstrate compliance monitoring for 12 CFR § 337.6.