About Ken Tumin

Ken Tumin founded the Bank Deals Blog in 2005 and has been passionately covering the best deposit deals ever since. He is frequently referenced by The New York Times, The Wall Street Journal, and other publications as a top expert, but he is first and foremost a fellow deal seeker and member of the wonderful community of savers that frequents DepositAccounts.

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Risks of Brokered CDs

Brokered CDs can have advantages over CDs that are purchased directly from banks or credit unions. I reviewed both the pros and cons of brokered CDs in this 2012 blog post. One important downside is the risk of brokered CDs especially when dealing with an unfamiliar brokerage firm. An example of this type of risk was recently described by DA reader ChrisCD who mentioned a website listing suspiciously high CD rates. As he described in the DA forum and in his blog post, there are many red flags. I’m not sure if that website is claiming to be offering brokered CDs, but it does raise the important point that when you’re going through a middleman like a brokerage firm for your CDs, it’s critical that the brokerage firm be a reputable deposit broker.

The FDIC recently published a guide on brokered CDs in its Spring Consumer News. Here’s an excerpt with advice about ensuring the reputation of the brokerage firm:

If you’re thinking about an offer from an unfamiliar deposit broker, research that person’s credentials and experience. If the person claims to hold any professional licenses or certifications, verify his or her background and standing with the issuing agency, such as FINRA (the Financial Industry Regulatory Authority at www.finra.org or 1-301-590-6500). In addition, your local Better Business Bureau (http://www.bbb.org/) or your state’s consumer protection office (www.consumeraction.gov/state.shtml) may be able to provide information about whether an individual broker or a company has a history of actual or alleged misconduct.

“We’ve heard multiple examples of individuals wiring funds to someone claiming to be a reputable broker, only to later find that the broker disappeared with all of the money,” said Calvin W. Troup, an FDIC Senior Deposit Insurance Specialist. “Whenever you use a third party to establish a bank deposit account, you place your funds at risk if that person does not put your money in an FDIC-insured bank.”

DA reader pearlbrown found a very useful tool inside the FINRA website called BrokerCheck. Here’s an excerpt from the BrokerCheck overview page:

BrokerCheck is a free tool to help investors research the professional backgrounds of current and former FINRA-registered brokerage firms and brokers, as well as investment adviser firms and representatives. It should be the first resource investors turn to when choosing whether to do business or continue to do business with a particular firm or individual.

When you see suspiciously high CD rates, it may not always be an illegal scam. The FDIC Consumer News describes two ways unscrupulous brokers advertise above-market rates on CDs. In both cases, they are using those high CD rates to get people in the door so they can market them other investments that offer big commissions. And in both cases, those high CD rates are very misleading. Here’s an excerpt from the FDIC describing the first example:

In one recent case, a high-rate brokered CD was issued by a foreign bank and therefore not protected by FDIC deposit insurance. However, the marketing materials for the CD included multiple misleading references to an FDIC-insured bank, and that led consumers to mistakenly believe that the investment was subject to FDIC insurance. In reality, the role of the FDIC-insured bank was limited solely to wiring collected deposits overseas to the issuing bank.

The second example involved the deposit broker advertising short-term CDs with very high rates. The high rate was the result of the broker adding in a bonus to make it look like the CD has a high rate. It’s a bait-and-switch strategy in which the broker is using the CD to attract customers for their other investments which of course have high commissions. I have more details on this scheme in in my post on very high CD rates advertised in newspapers.

The other parts of the FDIC Consumer News article describe other potential issues of brokered CDs. These other risks aren’t as serious as the risk of being scammed out of your money, but they could create some unpleasant surprises if you aren’t aware of them. They include the risk of having some of your deposits not insured, the risk of selling your CDs at a loss before maturity and the risk of delays if the bank holding the brokered CD fails.

Related Pages: CD rates
  |     |   Comment #1
Ken, you should mention that most of the individual investors money are pulled in a bigger pool of funds, sometimes in millions and the individual’s money may not be totally covered by FDIC either, because $100K invested may be just a small amount of the larger pool of money.
The banks that issue these CDs, most of the time are in the millions and very few individuals can buy it outright for themselves only.
In other words, your money is just a part of the CD issued by the bank and you are only a fractional owner of that CD. Should the bank goes under, your money is not 100% insured.
  |     |   Comment #3
#1  I think your information is in error.  You are right that the brokers purchase a large amount of CDs from the same  bank but once we purchase what we need, as long as we don't go over the insured amount, our CD is fully insured even tho it is a part of a larger group.  I was concerned about this years ago when I first started buying CDs from our brokerages and called the FDIC to make sure the info I was given was correct.  The FDIC rep told me if the bank failed, everyone who purchased CDs from that particular bank for the "insured" amount would be insured no matter how much the brokerage bought.  The FDIC does not pay back the brokerage in case of a bank failure, they deal with the customers who hold CDs from the failed bank.  Things work basically as they do if you had purchased the CD from the particular bank yourself. Your insured funds would be repaid and go into your brokerage money fund so you could buy another CD if you desired.  Just keep track that you don't go over the insured allowed amount for each bank you buy CDs from through the brokerage.
  |     |   Comment #4
#3 has it right for large, reputable broker-dealers like Fidelity and Vanguard, which maintain account records that, under FDIC rules, ensure "pass through" insurance coverage for CDs held by intermediaries on behalf of customers.  The bank's records show a "master" CD held for the account of customers, but the FDIC looks behind this CD and treats the customer as the owner of the individual piece shown on the broker's books.
  |     |   Comment #5
#4 If what you are trying to say is that the "Master CD" bought by the broker has to be within the $250,000.00, that is not what I was told.  This would mean that the broker has to be sure not to buy more than $250,000.00 of a CD from any one bank and I don't think that is how it works.  Maybe I will call my broker again to find out what the real deal is.
  |     |   Comment #2
Brokered CDs from a reputable broker do offer some convenience in that issues from multiple banks can all be managed from the same account, with separate FDIC insurance based on the holdings from each issuer.  However, there is a price to be paid in the form of a hidden commission which is the difference between the bank's actual rate and the rate received by the customer.  When rates were more reasonable, a spread of 0.25-0.50% might have been worth it for the convenience, but with today's rates, it's a deal-breaker.  Fidelity Investments, for example, has a 1-year CD from Discover at 0.30%, while the rate directly from the bank is 0.80%.  So if you're willing to do the extra paperwork and bookkeeping, the advantage goes to dealing directly with the bank.
  |     |   Comment #6
The "master CD" has no insurance limit under FDIC rules, because the agency looks through it to the customer of the broker to determine how much is owned and what is insured.  That's why it's considered "pass-through" insurance.
  |     |   Comment #8
Comment #2 is correct; but there's a LOT more to the story.

Here is the permanent URL for all the brokered CDs offered by Fidelity at whatever moment you look there.  On Monday afternoon they have 115 offerings, several of which are more than $8 Million apiece.  You can buy whatever you want in multiples of one thousand dollars.


5 years ago I bought several CDs at different maturities and different banks.  The rates offered through Fidelity were quite good.  But for the most recent couple of years the rates offered through Fidelity are LOUSY when compared with the rates offered directly by the same bank for the same maturity.

For example, today an Ally Bank 2-year CD offered on the Ally website has a rate of 1.04%, while the Ally CD with maturity date of June 12, 2015 is only 0.50%.  And there are three additional advantages by getting the CD directly from Ally that you don't get with the Fidelity brokered CD.  

(1) The Ally CD is raise-your-rate, allowing a one-time increase of the rate anytime during the 2 years if you see Ally offering a higher rate on its 2-year CDs, but that feature is not available through Fidelity;

(2) The Ally CD rate is actually 1.29% if you are rolling over a CD that is already at Ally -- they have a 0.25% loyalty bonus, which you do not get through Fidelity;

(3) On the CD through Fidelity you get interest only every 6 months, whereas through Ally you can have it sent to you monthly. 
  |     |   Comment #9
stay away from brokered cds in this low rate bernanke kill the savor mkt deal with a ncua credit union all earnings go to credit union members not to stockholders or overpaid bank ceo
  |     |   Comment #10
This is the problem I have. The broker is the middle man, he cuts a piece of the pie, but he told me that he pays insurance on the open market for being a broker and that insurance is just in case there is something out of balance when or if the broker goes out of business and keeps the money you gave it to him and he did not purchase your CD from the bank.

On the other side of the equation, the bank does not know who is in the pooled money and can not individually insure any person who bought brokered CD.

FDIC applies only if the bank fails but not the brokerage, because the money held in the pool at the brokerage is not insured by FDIC and if the money is not FDIC insured, then you have to file a law suit to collect, but if the broker counters with bankruptcy, you are out in the cold.

If the bank fails, FDIC asks the broker for the list of the individuals and the amounts that is insured under $250K, if you are above that at that particular bank, you will loose the rest of it.
  |     |   Comment #12
#10  I don't know what brokerage you are speaking of but they do have SIPC insurance for the money in their Money Fund accounts etc.  I just got off of the phone with my brokerage agent and he said the way it works is that even if the brokerage goes under, we will not lose a penny because the money in their cash accounts is covered by SIPC insurance.  As for the CDs, we would still have them with each bank which is holding them in the name on the CD.  We would deal with the bank directly if that particular bank failed and that money is FDIC insured. If our brokerage failed,   I would just do a Rollover transfer of all the CDs in the failed brokerage account to another brokerage of our choice. What you have to remember is that an IRA is just a basket to hold your choices in and can be rolled over to another bank or brokerage if you follow the rules and do it correctly.

Having CDs with a brokerage is not as simple as just holding them at a local bank.  There are pluses and minuses for this but over the years we have not had any problems with any of our brokerage CDs or the brokerage. 
  |     |   Comment #14
#10 you are correct, #12 you are wrong, #13 you are correct about SIPC.

There is a grey area when you cut a check to the broker and the time he sends it to the bank, it could be a month before your money reach the bank, in mean time the broker can do what ever he want to do with your money, nobody controls his/hers behavior.

  |     |   Comment #11
It would appear from the previous posts that no one is 100% sure about FDIC coverage on brokered CDs.  I call the FDIC and they would not give detailed information about them.  I'm staying far away from them!
  |     |   Comment #13
TO #12








  |     |   Comment #15
Stay away from Brokered CDs.  Even the FDIC won't provide any valid info about them!!!!!
  |     |   Comment #16
Maybe the discussion about this post piqued some interest in the broker-dealer world.  I just got an e-mail from Fidelity, which advised as follows:

"Generally, deposits at a bank held in nonretirement and qualified retirement accounts such as traditional or Roth IRAs are eligible for up to $250,000 coverage per account owner, per depository institution. Certain holdings at Fidelity are eligible for “pass-through” FDIC insurance coverage subject to these same limits.  
Eligible positions include:

 •  Certificates of deposit (CDs) — Brokered CDs that are issued by an FDIC-insured institution
 •  Core balances in the Fidelity® Cash Management Account1
 •  Core balances in eligible Fidelity IRAs or Fidelity Health Savings Accounts1
 •  Any 529 Bank Deposit Portfolio investments 

"Please keep in mind, monitoring your FDIC coverage is your responsibility. "
  |     |   Comment #17
#16   Your email from Fidelity is basically the same info I was given on the phone.  I think Fidelity wants to make sure people don't get too antsy about doing business with their brokerage. 
  |     |   Comment #18
Fidelity is just one of the thousands of brokers nationwide.

One thing to remember, the broker never specify which bank or banks or other investments created the blended rate of return,
It could be a mixture of 2,5,10 or more institutions were your money is being split or combined into just one bank.
On top of that, your money could be invested in a corporate CD without ever knowing about it.
Since you give the money to broker and expect them back from the broker, he could gamble your money away and pay you back somebody else’s money that is waiting to be invested.
There is a possibility of a ponzy scheme to happen.
  |     |   Comment #20
#18 & #19 :  It's one thing being very protective of those we do business with but what is this stuff you have against brokerages??  If we are to have your attitude, we should just stuff the money under our mattress and then not sleep all night worrying that the house will burn down!  ANY place we put our money can have problems.  The best we can do is go with the bigger more successful brokerages and do our part by making sure our money is protected.  Any CD we get from our brokerage always has the name, cusip number and other information for the bank it is purchased from.  If there are more than one of the banks in the US, I always insist I know just which one it was purchased from and what that particular bank's rating is.  Other than that, I can do nothing else. 

Now we have you saying it can be a Ponzi scheme??  So can ANY money we give to anyone for investment.  Maybe the teller I gave my interest checks to at the bank today gave me a "pretend" deposit receipt and put the money in her pocket instead??  It's good to be concerned about our money but this paranoia stuff is a bit much.  If I had to be that paranoid about the places I do business with, I wouldn't be doing business with them in the first place.  You want to know how careful I am with our funds?  I made sure I split DP's Rollover IRA between two brokerages instead of just one.  That way, if one brokerage gives me problems, I can just roll it all over into the other.  I am already more careful than most people but not to the point of what I have read today.  Fidelity has always been very trustworthy and never given us any problems over many, many years of doing business with them.  I don't think it is right for you to post parnoia crap unless you have proof of what you are posting.
  |     |   Comment #19
Paoli2,  You are too trusting of Fidelity or any other brokerage firm.  The person you talked to told you what is on their website.  Who knows what really goes on.
  |     |   Comment #22
I mean #20 above and not #29 (a typo).
  |     |   Comment #24
At least with Vanguard brokered CDs, the interest does not compound. It is paid out into a sweep or other designated account. I find that less than optimum. I should also note that brokered CD rates are less than those available to smart comparison (retail) CD buyers.
  |     |   Comment #25
If you have a brokered CD in an IRA account, the interest earned does not compound inside the CD but sweeps into a near zero rate paying money market account.  So it stays in that account earning near zero rates until there is enough in the account to make a change and invest it into another CD or transfer the IRA to another bank.  This brings up another point.  Most brokerages charge a fee to transfer IRA funds.  Discount brokerages charge about $25 for an IRA transfer but some of the full service brokerage houses charge $100 or more.   
  |     |   Comment #37
#25/35:  You must be a newbie here.  You can't take most things I post seriously.  I understood what you were doing and it wasn't a hate post.  I was just kidding about the subject.  I don't even hate stocks but I like to post about hating stocks.  Stocks can make people rich if they are lucky and guess which ones are the right ones to buy at the right time.  I just hate that I am not good at guessing about stocks. 
  |     |   Comment #26
So I guess this has been "hate the brokerages day".   I wonder what we get to hate tomorrow.  Can we do the entrie stock market and any thing to do with stocks?  That only seems fair.  Have a good night all!
  |     |   Comment #27
#26  Today is "I hate the stock market day".
  |     |   Comment #28
Oh Great!  We get to hear from all the folks who lost money in stocks! What a great way to start the day! :)  No fair anyone who made money on stocks posting.  I only want to read about the losers.
  |     |   Comment #29
paoli2, you asked for a "I hate the stock market day" and you got it. 
  |     |   Comment #21
#29, Fidelity is at the bottom of the pit when the rates are concerned and nobody uses Fidelity anymore for brokered CDs. In general the above comments are for high interest rate brokered accounts that carry a huge amount of risks. Some of them are one person company and hide behined a flashy web site with all kinds of lies and false disclaimers.

  |     |   Comment #23
#21  We still use Fidelity for the CDs to go into the IRA so there are people who still use them for brokered CDs.  You are right about one thing.  Their CD rates are too low.  I have griped to them about this quite a lot.  However, until interest rates go up, we are stuck.  When rates do go up, I am sure so will theirs.  In the past years, their CD rates were always about the same as outside bank rates but these last two years they have really gotten lower.

Would you please explain what are these " high interest rate brokered accounts that carry a huge amount of risks" that you are referring to?.  I have never seen anything like that on Fidelity's pages for CDs.  Are you sure Fidelity carries such things?  The only Fidelity CDs we buy are from individual banks. When I check Vanguard's CD page they usually are selling the very same CDs with the same interest rate.  I have never seen anything like what you are describing on Fidelity or Vanguard's CD page. I would never buy the type of CDs you are referring to.
  |     |   Comment #30
#29:  So??  Where are all the "haters"?  Do I have to do everything myself.  Defend brokerages and hate the stock market too??
  |     |   Comment #31
It will give you something to do.
  |     |   Comment #32
I can multi-task and this group is just "one" of my tasks so I don't need more to do.
  |     |   Comment #33
To , I tought you are much brighter than that comment.
  |     |   Comment #34
#33  I am so happy I was able to live "down" to your expectations.  BTW, your post makes no sense to me so I guess I am really not bright.  Have a good day. 
  |     |   Comment #35
  |     |   Comment #36
This is from the FDIC itself:

“The FDIC's insurance regulations include the following rule: "Funds owned by a principal or principals and deposited into one or more deposit accounts in the name of an agent, custodian or nominee, shall be insured to the same extent as if deposited in the name of the principal(s)." 12 C.F.R. § 330.7(a). In other words, the insurance coverage "passes through" the agent or custodian to the principal. "Pass-through" coverage generally is not available, however, unless the agency or custodial relationship "is expressly disclosed, by way of specific references, in the deposit account records' . . . of the insured depository institution." 12 C.F.R. § 330.5(b)(1).”

I have more if you want it.

We have never had problems with a brokered CD.  We did have problems with a direct CD.  It was akin to someone's post above about the teller stealing your money.  And yes it did take a lawsuit.  Very sad.  However, as Paoli pointed out, your house can also be burned down or robbed so keeping all of your money there isn't the smartest move either.

Brokerages and Safekeeping agents have audits and have to match money that came in and where it was invsested.  In the case of the CD, the system and paper trail has to show that the brokerage is holding a CD for you.

Yes brokered CD rates stink at this point in time, but you can't beat their ease.  For high net worth individuals hunting around probably makes sense.  For people like me, it would take far too much time for the yield I would receive.  Personally, I use Charles Schwab.

For the record, I lost on an Apple Stock purchase.  Now the stock market haters can be happy.  At least I know with my CDs that my principal will be returned.  :O)
  |     |   Comment #38
#36,  I was wondering if you have noticed that most of the time you will find that the majority of the C.D.'s offered through Charles Schwab are from Goldman Sachs and most of the time they are sold in the secondary market and pay the highest yield to maturity rate.   It has seemed a little unusal to me and I have never been able to find out from Schwab why Goldman Sachs CD's always are on the top of their offering list.
  |     |   Comment #39
#38 Don't mean to intrude on your post to #36 but your post brings up a question that I have wondered about also.  You see I notice that Fidelity and Vanguard usually always have Goldman Sachs Cds for sale and I just recently bought one because the rate was just a "bit" higher than other CDs they both had.  I never buy CDs off of their Secondary market.  However since these CDs are usually ones others have bought and trying to sell and there seem to be more of Goldman Sachs than most others, could it be because buyers are wary of trusting them due to some bad publicity? 

If they are at the top of the list on the secondary market and giving higher yields than others, I would think the seller is eager to sell them.  This is the main negative I find with brokered CDs.  You can't just pay an EWP and get your full principal back.  They make sure we know that they don't even guarantee you will be able to sell the CD on the Secondary market if you need to sell.  This is why I only buy CDs from brokerages for the IRAs we have with them.
  |     |   Comment #40
Another aspect is to look at the financial statements (or "current interest rate" sheet) from banks that may take "brokered accounts."  First, FDIC limits banks that are "in, or close to, trouble" to the amount of brokered CDs that bank can accept...reason primarily being those individuals are not long term customers of that institution and "will run" when things so south.  Second, try not to use banks that take brokered accounts when that bank (through the broker) is offering the "higher rate" than the bank is directly offering to the public...the bank does not treat its "long-term" customers with greater interest (pun intended).
  |     |   Comment #41
#40 Interesting info but I don't think any of the banks I deal with sell brokered CDs.  I have only gotten them from brokerages.  Thanks for the additional info.
  |     |   Comment #42
#40  Your past posts have stated you bank with Chase.  I have seen brokered CDs from Chase.  FYI....
  |     |   Comment #43
#42 Are you referring to me #41?  I had no idea Chase has brokered CDs.  I will call them in the morning just to see what the difference is in the rates if they have any.  Thanks.
  |     |   Comment #44
#43  I was referring to you.  My post  had a typo. 
  |     |   Comment #46
#40  I just got off of the phone with my local Chase.  You were so right on about the 2 step except it was more like a 5 Step.  First, she never heard of them having brokered CDs then after I persisted she said she thinks it is only for their new Private Client customers.  I am a Premiere customer but it seems that is different from a Private Client since they know I use a lot of other banks and sources for my funds.  She is now trying to find me a local Private Client agent to talk to about this and supposedly, he/she can explain more about the brokered CDs to me.  However, it seems you have to buy what they offer "in bundles" which are more than the brokered CDs.  This "mystery" is getting very interesting to me so I am determined to find out more about what is going on with this.

Thanks #40 for bringing this to my attention. 
  |     |   Comment #51
#40  I have reason to believe you are so right because today on the phone everytime I tried to make it clear to my local Chase rep that I was only interested in CDs she kept saying "CDs are not the only products they offer.  They offer you the "whole" package".  However she conveniently did not know what came in the "whole" package and you can't seem to be offered brokerage CDs unless you are willing to go for the "whole" package.  I think the "whole" package includes products that are not FDIC insured because on their webpage for Private Client Info it does mention not all products are FDIC insured.  2 and 2 still makes 4 in my book and that tells me a lot about the program.  I think I will keep my "privacy" to myself and continue handling my own finances.
  |     |   Comment #45
I'm #40...when "you" contact the bank it will generally do a "two-step."  Why?  B/c the brokered accounts are not handled "locally."   Again, need to look at the current interest rate sheet and generally see that "brokered accounts" are excluded from posted rates...and the financials usually address some aspect of brokered accounts.  Thus, "one" may have to "push them" to find out why the bank offers a higher rate to non-customers, i.e. the brokered accounts!


Have a great week!
  |     |   Comment #47
paoli2, I believe #42 brought this to your attention..
  |     |   Comment #48
#47:  You are right.  I got all the numbers mixed up.

#42:  Thank you for bringing this to my attention.  It seems you are so right about Chase.  Now they are saying they can't even let me have info about their brokered CDs unless I go to a meeting with a Private Client Agent so they can get to know me better.  I have been a client with Chase in my hometown and here for years.  I told her I am not looking for friends, I am looking just for higher CD rates so I am not available for any "get to know you" meeting.  I would love to hear from someone who is one of their Private Clients to find out what all the mystery is about.   If they have better CD rates available, even if brokered, they should at least let their Premiere customers have access to them.  So thanks again #42 for letting me know about this.  
  |     |   Comment #49
The question was asked why some banks always seem to have the highest rates such as Goldman Sachs.  It is hard to know exactly, but one may be they just don't want to fool around with funds coming in here and there so they just go for the top.  The other could be a perception of needing to overcome some concern with reputation.  So pay a higher rate, people like you more.  Lastly (although not necessarily finally), they want to make it easy for people to pick them.  Those at the top will get the most looks.  :O)
  |     |   Comment #50
This is #40...you will find that private client agents will generally not offer FDIC guaranteed accounts but "investments" from a subsidiary, non-bank, or from an insurance company.  Thus if a bank offers/receives brokered accounts (and, again, its financials and/or interest rate sheet will indicate same) the focus is where the bank provides FDIC guarantees...which is what the brokerage houses and this thread are focusing on and why a higher FDIC rate than that offered its "regular" customers of a FDIC bank.   
  |     |   Comment #52
When it comes to brokerage houses, CDs are usually one of the lowest paying commission vehicles they have.  Thus the reason they would want to show you something else (for their pocket books, not yours). 

And I believe Ken touched on it, but that is why you sometime see a 'too good to be true" rate in the newspaper.  A firm wants to get you in the door with the offer of the CD, but they hope you will buy something else.  They use the higher commisssions from those that do buy something else to pay for the offset they end up having to pay to a small percentage that insist on the CD.  These type of deals often have the maximum principal that can be invested in the CD set quite low which also keeps their exposure low.
  |     |   Comment #53
Possibly being a "Private Client" you have Jamie Dimon managing your money!
  |     |   Comment #54
#53  You may think you are joking but I think basically that is what it is all about.  They want access to all my finances to manage it the way Dimon would want it managed.  I am sure I would be told I am not "diversified" enough etc. etc.  Jamie Dimon can probably afford to lose thousands of dollars in riskier products and recover.  I am past the age where I can recover lost money.  That was funny what you posted because I think you are closer to the truth than you can imagine.  After all, who do you think makes or approves the decisions for what the Private Client agents do with their clients?.  The Big Guy may have come up with this idea.  It may help certain people but it is not for me.
  |     |   Comment #55
  |     |   Comment #56

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