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The FDIC’s 2026 interim final rule expands the amount of reciprocal deposits that eligible agent institutions may exclude from brokered-deposit treatment and broadens one route to agent-institution eligibility. The amended cap is based on total liabilities, uses three percentage tiers, and tops out at $30 billion. The American Bankers Association (ABA) welcomed the rule, while reporting instructions for the September 30, 2026 Call Report were still being updated in the rule’s account of implementation.
What reciprocal deposits are—and why the rule matters
Reciprocal deposit arrangements allow a bank to place a customer’s funds through a network so the depositor can obtain expanded deposit-insurance coverage while maintaining a relationship with the bank. Under the statutory exception, qualifying reciprocal deposits can receive different treatment from brokered deposits, up to an applicable cap. The exception is relevant to banks’ funding and regulatory reporting; this is a rule for insured depository institutions, not a change to the general deposit-insurance limit.
The FDIC’s interim final rule implements amendments made by section 902 of the 21st Century ROAD to Housing Act. The Act took effect July 11, 2026, and the Federal Register published the rule on September 1, 2026. The notice invited comments through October 1, 2026, a deadline that had passed by October 3, 2026. Federal Register notice
How the new reciprocal-deposit cap is calculated
For an eligible agent institution, the amended general cap is calculated in liability tiers. Each percentage applies only to the portion of liabilities within that tier—not to the institution’s entire liability total. The amount that may be excluded under the cap cannot exceed $30 billion. FDIC rule and explanation
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| Total-liability portion | Percentage applied |
|---|---|
| First $1 billion | 50% |
| Above $1 billion through $10 billion | 40% |
| Above $10 billion through $96.333 billion | 30% |
| Liabilities above $96.333 billion | No additional amount under the tiers; the cap is limited to $30 billion |
FDIC example: $25 billion in liabilities
For an institution with $25 billion in total liabilities, the FDIC’s calculation is $8.6 billion: (50% × $1 billion) + (40% × $9 billion) + (30% × $15 billion). The FDIC says it will continue calculating the cap using Call Report data. The $8.6 billion is a worked regulatory example, not a measured outcome. FDIC rule and explanation
How this differs from the prior cap
Under the earlier framework, a qualifying well-capitalized and well-rated institution could exclude the lesser of 20% of total liabilities or $5 billion. The 2026 formula replaces that general calculation with liability tiers and a maximum of $30 billion; the amount available to any institution still depends on its liabilities and eligibility. FDIC rule and explanation 2018 FDIC rule
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Which banks can qualify as agent institutions
The first statutory eligibility prong now includes an institution with a CAMELS composite rating of 1, 2, or 3—or an equivalent rating under a comparable rating system—at its most recent examination. The institution must also be well capitalized. The other two statutory prongs remain unchanged; the rating amendment does not, by itself, establish eligibility. FDIC rule
The FDIC’s rule implements the statutory cap and eligibility changes through Part 337 and includes additional clarifications intended to simplify compliance. Banks should assess eligibility against the full statutory criteria and applicable Part 337 requirements rather than relying on the CAMELS rating alone.
What banks need to know about Call Report timing
The rule addressed reporting for the September 30, 2026 Call Report, stating that the FFIEC would issue supplemental instructions so institutions could report brokered and reciprocal deposits consistently with the new law. It anticipated conforming Call Report instructions by December 31, 2026, said no new Call Report line items would be needed, and anticipated working through the FFIEC to make Schedule RC-O, item 9 (brokered reciprocal deposits) confidential. These were forward-looking statements in the rule, not confirmation that every reporting change was finalized. Consult current FFIEC instructions before preparing or amending a filing. FDIC rule
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What the ABA welcomed—and what remains an advocacy position
The ABA welcomed the clarifications and described reciprocal deposits as an important source of stable, diversified funding for many member banks. It said these arrangements can help banks retain existing customer relationships while offering depositors expanded insurance coverage through a single banking relationship. Those are the ABA’s stated views; the cited ABA coverage does not establish measured effects on funding stability, deposit retention, lending, or economic growth. ABA Banking Journal report
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The ABA also argued that reciprocal deposits can help banks compete for and retain deposits that might otherwise leave their communities, supporting their capacity to meet local credit needs. It presented the rule as a possible first step toward broader reconsideration of Federal Deposit Insurance Act Section 29, which governs brokered deposits. These are policy arguments, not findings quantified by the rule or the ABA report. ABA Banking Journal report
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