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DIM_BROKER_DEPOSIT_TYPE filter changes for RC-E M.1.F(K223) FFIEC031/041 (Doc ID 2699287.1)

Last updated on AUGUST 12, 2020

Applies to:

Oracle Financial Services - Regulatory Reporting for US Federal Reserve - Lombard Risk Integration Pack - Version 8.0.8 and later
Information in this document applies to any platform.


Usage of seeded values from table DIM_BROKER_DEPOSIT_TYPE in reg reporting USFED

1. The usage of the following values require a clean-up: Both values of OTHBRDEP and NONREC appear to be a catch-all bucket for values and are not
reciprocal deposits. Open question is how are the 2 different. Only 1 should exist to remove ambiguity

(a) OTHBRDEP (Other Brokered Deposits) Other brokered deposits that do not fall into the above categories include certificate of deposits that are originated through brokers - Observation is that if intent is to source a specific value such as certificate of deposits that are originated through brokers, then use a specific broker type code instead of Other Brokered Deposit

(b) NONREC (Non-Reciprocal Deposits) Refers to non reciprocal brokered deposits that do not meet the criteria of reciprocal deposits these do not include brokered sweeps and brokered certificate of deposits - Please confirm if this is the catch-all value or the value in point (a)

2. RC-E memo line M.1.f (K223) that is required to report Estimated amount of deposits obtained through the use of deposit listing services that are not brokered deposits is based on logic of NOT BRSWEEP, NOT NONREC, NOT OTHBRDEP, NOT RECDEP.
Fed instruction for this MDRM has "The objective of this Memorandum item is to collect the estimated amount of deposits obtained as a result of action taken by the bank to have its deposit rates listed by a listing service, and the listing service is compensated for this listing either by the bank whose rates are being listed or by the persons or entities who view
the listed rates."
DIM_BROKER_DEPOSIT_TYPE has value NONBRLISTDEP (Non Brokered Listed Deposit) with description 'These are deposits that were listed by deposit listing
service provider that are acquired'. Please clarify the use of this value and whether it applies for RC-E. Whether RC-E logic for K223 should use this value directly instead of a NOT logic. Is this value mutually exclusive with other non-brokered depsoit values NBRRECDEP and NBRSWEEP

3. BRSWEEP and NBRSWEEP: Fed instructions have text around retail sweeps but do not appear to have any MDRM where sweeps are separately called out for reporting. While logic is using BRSWEEP in MDRMs that report brokered deposits (RCON2365, RCONHK05, RCONHK06, RCONK220) and NOT BRSWEEP for RC-E memo line M.1.f (K223), the need to have separate values and used in RC-E is
not clear.




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