BankingLENS

Banking benchmarks

Brokered deposits and wholesale funding: how much is too much?

Published October 10, 2026. Every figure computed from FFIEC call reports for the quarter ending June 30, 2026.

Short answer: The median bank has no brokered deposits at all. Of the 4,238 banks these benchmarks cover, 1,930 reported any for the quarter ending June 30, 2026, the top quartile starts at 4.32% of deposits, and 519 banks are above 10%. No ratio is automatically too much. What matters is whether the bank is well capitalized, because the law restricts brokered funding the moment it is not, how much of the money matures inside a year, and whether it is paying for growth the bank's own deposit base could not.

What counts as a brokered deposit

A brokered deposit is one a bank obtains from or through a deposit broker: a person or firm in the business of placing other people's deposits at insured banks, or helping them do it. The familiar example is the certificate of deposit sold through a brokerage firm. Some sweep programs and some deposits that arrive through a technology partner count too.

The line is drawn by rules the FDIC rewrote in 2020, which exempt a number of arrangements, such as a partner that places deposits at only one bank. A 2024 proposal to tighten those rules was withdrawn in March 2025, so the 2020 framework stands. Two near neighbors fall outside the definition. Reciprocal deposits are treated as not brokered, up to the lesser of $5 billion or 20% of total liabilities, at a bank that is well capitalized and well rated. And deposits gathered by posting a rate on a listing service are generally not brokered, though they behave much the same.

Every bank reports its total on Schedule RC-E of the call report, in the memoranda, as RCON2365. That is the numerator here. The denominator is total deposits.

What is normal, by bank size

Bank size (total assets) Banks Bottom quartile Median Top quartile Banks with any Banks over 10%
All banks4,2380.00%0.00%4.32%1,930519
Under $100M5430.00%0.00%0.00%9831
$100M - $300M1,2140.00%0.00%2.41%427108
$300M - $1B1,4330.00%0.00%4.15%690168
$1B - $3B6260.00%1.22%7.37%395122
$3B - $10B2640.00%1.97%8.83%18859
$10B - $100B1260.06%3.69%8.93%10124
Over $100B322.58%4.75%7.79%317

Source: BankingLENS, computed from FFIEC call reports for the quarter ending June 30, 2026. Quartiles are calculated across the full population of filing banks in each size band, not sampled. Non-insured non-deposit trust companies are left out of every statistic: they take no deposits and make no loans, so a margin or a funding cost computed for them has no meaning.

Brokered deposits are RCON2365 from Schedule RC-E, as a share of total deposits, and every bank in the population reports the line. The last two columns count banks, not percentages: those reporting any brokered deposits, and those where they exceed 10% of deposits.

Use of brokered funding climbs steadily with size. Under $100 million, 98 of 543 banks report any, about 18%. Above $100 billion, 31 of 32 do, and the median bank there funds 4.75% of deposits this way. The median first leaves zero in the $1 billion to $3 billion band, at 1.22%.

Heavy use follows a different pattern. Among banks of $1 billion and up, about one in five is above 10% of deposits, and that share barely changes from one size band to the next. Below $1 billion it is under one in eight. Across all sizes 206 banks are above 20%, which puts a bank in roughly the top 5%, 80 are above 30% and 25 are above 50%. At those levels brokered funding is usually the business model and not a patch, as it is at banks with few or no branches.

What the law does when capital slips

The restriction that matters is in Section 29 of the Federal Deposit Insurance Act, and it turns on the bank's capital category.

Capital category Brokered deposits Deposit rates
Well capitalizedMay accept, renew and roll over freely.No cap.
Adequately capitalizedOnly with a waiver from the FDIC.May not pay significantly more than prevailing rates.
Undercapitalized or worseNot at all.May not pay significantly more than prevailing rates.

Well capitalized means a total risk-based ratio of at least 10%, tier 1 risk-based of at least 8%, common equity tier 1 of at least 6.5% and a leverage ratio of at least 5%, with no written order requiring the bank to hold a specific level of capital. A community bank that has elected the community bank leverage ratio is well capitalized above 9%.

Two things about that table catch banks out. The first is the last clause of the note: a bank under a formal capital order is not well capitalized whatever its ratios say, so access can end with a signature and not with a loss. The second is that the restriction covers renewals and rollovers. A bank that loses its standing cannot replace brokered certificates as they mature, so the money leaves on the maturity schedule, at exactly the moment the bank would least choose.

For most banks this is distant. The median bank's tier 1 leverage ratio is 10.96%, more than twice the 5% the definition asks for. But the banks that lean hardest on brokered money are often the ones growing fastest, and fast loan growth is what uses capital up.

What it costs beyond the rate

There is one thing in its favor that the ratio hides. The holder of a brokered certificate usually cannot redeem it early, so the bank knows the day the money leaves. In a panic, a ladder of brokered certificates can be steadier than a base of large uninsured operating accounts that can go by wire in an afternoon (how much uninsured deposits is too much?).

It can also be the cheaper choice. Raising the rate on a money market account reprices every dollar already in it. A brokered certificate costs more per dollar and reprices only the new money. Well-run banks use brokered funding for exactly that reason, and in measured amounts.

Brokered is only part of wholesale funding

Brokered deposits are one of several ways a bank buys funding instead of gathering it. The others are Federal Home Loan Bank advances, federal funds purchased, repurchase agreements, large time deposits priced to attract them, and listing-service deposits. A bank with no brokered deposits can still be heavily wholesale funded through advances. The benchmark file behind this page carries brokered deposits but not the borrowings, so read the brokered share with the funding measures around it.

Measure, all banks Banks reporting Bottom quartile Median Top quartile
Brokered share of deposits4,2380.00%0.00%4.32%
Loans to deposits4,23865.73%80.16%90.94%
Noninterest-bearing share of deposits4,23815.03%20.98%27.73%
Cost of deposits4,2301.37%1.76%2.19%
Estimated uninsured share of deposits99823.76%32.08%42.10%

Source: BankingLENS, computed from FFIEC call reports for the quarter ending June 30, 2026. Quartiles are calculated across the full population of filing banks in each size band, not sampled. Non-insured non-deposit trust companies are left out of every statistic: they take no deposits and make no loans, so a margin or a funding cost computed for them has no meaning.

The uninsured row covers the 998 banks that report the line, almost all at or above $1 billion in assets, and is not an industry figure.

The combination to watch is a bank above the top quartile on both of the first two rows: more than 90.94% loans to deposits and more than 4.32% brokered. That bank is lending out more than its own customers give it and buying the difference (loan-to-deposit benchmarks). A low noninterest-bearing share, under 15.03%, and a cost of deposits above 2.19% point the same way (cost of funds benchmarks).

So how much is too much?

There is no regulatory ceiling for a well capitalized bank, so the useful reference points are these. Half of all banks have none. Three quarters are under 4.32% of deposits. Ten percent of assets is where a small bank's insurance pricing starts to respond. Above 20% of deposits a bank is in roughly the top 5% of the industry and should expect to explain itself.

The explanation matters more than the level. The FDIC's 2011 study of core and brokered deposits found that banks relying more heavily on brokered deposits were more likely to fail and cost the insurance fund more when they did, and that heavy use went together with fast growth and riskier loans. The deposits were the fuel, not the fire. These are the questions that separate the two.

Frequently asked questions

How much brokered deposits is too much for a bank?

There is no fixed limit for a well capitalized bank. For the quarter ending June 30, 2026, the median bank reported none, the top quartile started at 4.32% of deposits, and 519 of 4,238 banks were above 10%. Examiners look at why the funding is there, how fast it has grown and when it matures more than at the ratio.

What is a brokered deposit?

A deposit a bank obtains from or through a deposit broker, meaning a person or firm in the business of placing other people's deposits at insured banks. Certificates of deposit sold through brokerage firms are the familiar example. Banks report the total on Schedule RC-E of the call report.

Can any bank accept brokered deposits?

Only a well capitalized bank can do so freely. An adequately capitalized bank needs a waiver from the FDIC to accept, renew or roll over brokered deposits, and an undercapitalized bank cannot accept them at all. Banks that are not well capitalized are also limited in the interest rates they can pay on deposits.

Are reciprocal deposits brokered deposits?

Up to a limit, no. Since 2018 a well capitalized, well rated bank can treat reciprocal deposits as not brokered up to the lesser of $5 billion or 20% of its total liabilities. Amounts above that limit, and reciprocal deposits at a bank that does not qualify, count as brokered.

Do brokered deposits raise FDIC insurance costs?

They can. For a small bank, brokered deposits above 10% of total assets raise the rate it pays for deposit insurance. Reciprocal deposits are left out of that test when the bank is well capitalized and well rated.

What is wholesale funding?

Funding a bank buys in the market instead of gathering from its own customers: brokered deposits, Federal Home Loan Bank advances, federal funds purchased, repurchase agreements and large rate-driven time deposits. Examiners add these up as non-core funding and compare them with the bank's longer-term assets.

Where these numbers come from

Every bank figure on this page is computed from FFIEC call reports for the quarter ending June 30, 2026, across the 4,296 banks that filed for the quarter, less the 58 non-insured non-deposit trust companies that take no deposits and make no loans, which leaves the 4,238 banks these benchmarks are computed over. Nothing is modeled or sampled. Where a line is reported by only part of the industry we say so. The capital categories and deposit rules described are the federal ones in effect in October 2026. You can see brokered share, deposit mix and funding cost for a real bank, ranked against its FFIEC peer group, on the sample scorecard, or open your own bank in the dashboard. Plans that cover your state or every bank start at $29 a month (pricing).

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