Legal Disclosures

(Last Modified: April 1, 2024)

R&T Deposit Solutions’ Services

Reich & Tang Deposit Networks, LLC, Reich & Tang Deposit Solutions, LLC and Total Deposits Solutions, LLC (each d/b/a R&T Deposit Solutions) and Stable Custody Group II LLC, each a Delaware limited liability company, and/or their affiliates (together, “R&T”, “us”, “our” or “we”) provide administrative, recordkeeping, agency and/or other services to banks, credit unions, trust companies, wealth management firms, broker-dealers and other institutions with respect to sweep and deposit placement programs, including the Demand Deposit Marketplace® (“DDM®”) program and R&T Insured Deposits (“RTID®”) program. The DDM program is administered by Stable. The RTID program refers to both (i) the RTID program administered by Reich & Tang Deposit Solutions, LLC and (ii) the Insured Deposits Program (“IDP”) administered by Total Deposits Solutions, LLC (sometimes referred to as the ‘RTID (Legacy IDP) program’. R&T also provides other services, including a Loan Management System (“LMS”) service and the R&T Bank Monitor service.

R&T’s services are provided subject to the terms and conditions of the written agreements entered into between R&T and our client with respect to those services, and we provide no representations or warranties, express or implied, except as expressly set forth in those agreements.

R&T provides services to clients that are banks, credit unions, trust companies, wealth management firms, broker-dealers and other institutions that enter into a written agreement with R&T for those services (“Clients”). R&T does not offer or provide products, programs or services to consumers or to our Client’s customers (“Customers”). The services offered by R&T are only available to Clients that are residents of the United States of America. References to programs administered by R&T or to R&T’s services on our public website (at www.rnt.com) or in marketing or other materials should not be considered a solicitation to buy products or services or an offer to sell products or services to any person. Eligibility for certain programs and services may vary. These Legal Disclosures do not take the place of any legally required disclosures for any programs administered by R&T that are offered by our Clients to its Customers.

Important Legal Disclosures:

R&T is not an FDIC or NCUA-insured institution. FDIC and NCUA insurance only covers the failure of an FDIC or NCUA-insured institution, respectively. Certain conditions must be satisfied for FDIC and NCUA pass-through deposit insurance coverage to apply. Click here for a list of the FDIC and NCUA-insured institutions with which R&T has a business relationship for the placement of deposits under the DDM and RTID programs, and into which a participating institution may place deposits (subject to the terms of those programs and any opt-outs by the participating institution and/or its customers). While the DDM and RTID programs provide access to an expanded level of FDIC or NCUA insurance coverage on funds placed into the programs (up to the program limit and subject to program terms and FDIC and NCUA laws and regulations, including FDIC and NCUA pass-through insurance coverage requirements), the DDM and RTID programs, themselves, as well as R&T’s other service offerings (including LMS, FPL and R&T Bank Monitor), are not insured or guaranteed by the FDIC or NCUA, are not deposits and may lose value in certain circumstances as described in the program/service terms.  R&T is not a division of the FDIC or NCUA, R&T is not associated with the FDIC or NCUA and R&T is not insured by the FDIC or NCUA. 

The DDM and RTID Programs

R&T provides administrative, recordkeeping, agency and/or other services to its Clients with respect to the DDM and RTID programs, subject to R&T’s written terms, agreements and disclosures relating to those programs.

Under the DDM and RTID programs, an institution participating in the program acts as custodial agent for its customer to sweep or place its customer’s cash balances into deposit accounts at other Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Share Insurance Fund administered by the National Credit Union Association (for ease, “NCUA”)-insured institutions participating in the program. Those funds are allocated to the receiving institutions in increments of up to the then-current standard maximum deposit insurance amount (“SMDIA”) (currently, $250,000), per eligible depositor (e.g., based on TIN), per receiving institution, up to the relevant program limit. The result is that a participating institution can offer its customers access to an expanded level of FDIC or NCUA deposit insurance coverage on their funds (up to the program limit and subject to program terms and FDIC and NCUA laws and regulations, including FDIC and NCUA pass-through insurance coverage requirements). Until the customer’s funds are deposited into, and received by, the deposit accounts at the receiving institutions, the customer will not receive access to expanded FDIC or NCUA deposit insurance coverage on their funds under the DDM program.

Under the DDM and RTID programs, customer funds could, at any time, be allocated to and placed at any receiving institution that is listed on the sending institution’s list of receiving institutions in its program (other than a receiving institution that the customer has excluded (or ‘opted-out’ of)). Accordingly, customers should regularly monitor review their institution’s list of receiving institutions in their program and immediately notify their institution if they want to exclude (or ‘opt-out’) of a particular receiving institution from holding its funds. Customers should contact their participating institution to receive the list of FDIC or NCUA-insured receiving institutions into which that customers’ funds may be placed, at any time, pursuant to its particular program.

Both the sending institution and its customers can ‘opt-out’ of placing funds at any receiving institution in the DDM or RTID program (subject to program terms and limitations1). If a customer holds any funds at a receiving institution outside of the DDM or RTID program offered by the customer’s participating institution, when combined with the customer’s deposits held at that receiving institution through the DDM or RTID program offered by that institution, the total amount of the customer’s deposits held at that receiving institution could exceed the SMDIA for an FDIC or NCUA legal ownership category, and those excess funds will not be FDIC or NCUA-insured. Accordingly, if a customer holds any funds at a receiving institution outside of the program offered to the customer by its institution (whether directly or indirectly, including through other intermediaries, such as a broker-dealer or another deposit placement network), the customer should exclude (or ‘opt-out’ of) that receiving institution from receiving funds under the program. If a customer places funds into the DDM or RTID program through more than one sending institution, the customer should exclude (or ‘opt-out’ of) the same receiving institution from receiving funds under more than one such program (as customer funds are allocated to receiving institutions and tracked based on a customer identifier, which may be the customer’s TIN or a unique identifier provided to R&T by the sending institution).

Click here for a list of the FDIC and NCUA-insured institutions with which R&T has a business relationship for the placement of deposits under the DDM and RTID programs, and into which a participating institution may place deposits (subject to the terms of those programs and any opt-outs by the participating institution and/or its customers). Customers should liaise with their participating institution to obtain that institution’s list of receiving institutions in its particular program offered to the customer.

The maximum amount of FDIC or NCUA deposit insurance coverage that a sending institution’s customer may be eligible to access under the DDM and RTID programs is the relevant program limit set, from time to time, by that sending institution (the “program limit”), and is subject to the program terms and conditions and applicable FDIC and NCUA laws and regulations (including FDIC and NCUA flow-through insurance requirements). The program limit is generally based on the number of receiving institutions in the particular program offered to the customer by its institution. Customers should contact their participating institution to receive the program limit for its program. For the DDM program, the sending institution’s program limit offered to its customers must be less than the overall limit for the DDM program set from time to time by R&T, known as the “DDM Program Limit” (which can be found at https://rnt.com/our-solutions/demand-deposit-marketplace-program-ddm/). Any funds placed into the DDM or RTID program above the relevant program limit are placed into deposit accounts at ‘excess’ receiving institutions and are not eligible for access to FDIC or NCUA deposit insurance coverage.

R&T does not offer or provide the DDM or RTID program directly to the sending institution’s customers. Instead, the sending institution offers its particular program to its customers (and R&T administers that program for the sending institution). Accordingly, before a sending institution’s customer places any funds into a program administered by R&T, the customer should carefully read their institution’s particular program terms and conditions or agreements for important disclosures, terms, conditions, risks, customer eligibility requirements, limitations and other information relating thereto. Customers should contact their participating institution to receive a copy of those terms and conditions and disclosures. By participating in the program, the customer appoints its participating institution as its custodial agent to place and hold funds at the receiving institutions under the program (and authorizes its institution to appoint other agents and service providers, including R&T with respect thereto).

While customer rates obtained on funds placed into the DDM and RTID programs may, under certain circumstances, outperform cash alternatives, such as money market funds, the primary objective of the programs is to provide customers with convenient access to expanded FDIC and/or NCUA insurance coverage on their funds (and not for investment enhancements, or higher rates of returns or profits). If a participating institution (or its customer) is subject to any laws, regulations, restrictions or other requirements on the placement or deposit of their funds, such as a law governing municipal or government agency deposits, that institution or customer is solely responsible for determining whether its use of the DDM or RTID program satisfies those laws, regulations, restrictions or requirements and for complying with them.

R&T makes no representations or warranties, express or implied, with respect to a bank or financial institution’s classification of deposits as brokered or not brokered. Such determinations are entirely and solely the responsibility of that bank or financial institution.

Loan Management System (LMS)

R&T provides the loan management system (“LMS”) service, subject to its written terms, agreements and disclosures relating to that service. Under this service, (i) R&T licenses to a lender the ability to use R&T’ Loan Management System – composed of a Loan Origination Module (“LOM”), a Loan Underwriting Module (“LUM”), and a Collateral Monitoring Module (“CMM”) – to extend and monitor securities-based lines of credit (“SBLOCs”) that are custodied by a financial institution at which an underlying customer holds a securities account and (ii) R&T licenses to the financial institution with which the customer has its relationship (which may be the broker-dealer or trust company that acts as custodian or an investment advisor) the ability to use the LOM to facilitate a customer’s completion of an SBL application to the lender, which is stored and transmitted using the LMS. Under the LMS service, the lender also can use the LUM to underwrite the loan using its own credit criteria entered into the LUM, and the CMM to obtain the value of the customer’s pledged securities at the time the SBLOC application is underwritten and for monitoring the continued conformance to loan value standards established by the lender. The lender, financial institution and customer are solely responsible with respect to the underlying loan and securities transactions for which the LMS is used, and R&T has no liability or responsibility with respect thereto.

R&T Bank Monitor

R&T provides the R&T Bank Monitor service, subject to its written terms, agreements and disclosures relating to that service.  The R&T Bank Monitor service, clients subscribe to the service, which uses publicly available information to calculate and report safety and soundness metrics of active FDIC-insured depository institutions.

R&T’s Public Website

R&T’s public website, located at www.rnt.com, is offered, and may only be accessed and used, subject to the Website Terms of Use and our Privacy Policy as those document are posted on that website from time to time.

Client & Customer-Only Sites

R&T may permit access to website portals or platforms by its clients (e.g., banks, credit unions, trust companies, wealth management firms, broker-dealers and other institutions that enter into a written agreement with R&T) (“Clients”). In addition, R&T may permit access to website portals or platforms by customers of R&T’s Clients (“Customers”). Such portals or platforms are referred to as the “Client & Customer-Only Sites”.

With respect to our Clients, the Client & Customer-Only Sites are governed by (i) the applicable written agreement entered into between R&T and the Client with respect to services provided by R&T to our Client, (ii) if applicable, the Terms of Use (for Client & Customer-Only Sites) and (iii) our Website Terms of Use. In the event of any inconsistency between the terms and conditions of such documents, the order of precedence of those terms shall be (i), (ii) and (iii).

With respect to our Client’s Customers, the Client & Customer-Only Sites are governed by (i) if applicable, the Terms of Use (for Client & Customer-Only Sites) and (ii) our Website Terms of Use. In the event of any inconsistency between the terms and conditions of such documents, the order of precedence of those terms shall be (i) and (ii).

No Legal, Investment or Other Professional Advice

R&T does not offer or provide, and nothing (including on our public website at www.rnt.com) shall be construed as R&T providing, any tax, accounting, investment, legal or other professional advice or recommendation. Also, nothing shall be construed as being an offer to sell or a solicitation of an offer to buy any security. Without limiting the foregoing, R&T does not offer or provide any professional, legal or investment advice or recommendation regarding the nature, potential value, or suitability of any particular program, product, service, transaction, investment strategy, or other course of action by a person, including any Client or Customer. Prior to the execution of any transaction involving information received from or through R&T (including on R&T’s public website at www.rnt.com), the person should consult its financial, business, legal, tax and accounting advisors and/or attorney with respect to the price, suitability, value, risk or other aspects of any program administered by R&T or any product or service provided by R&T.

Forward Looking Statements

Certain information on in marketing or other materials (including on R&T’s public website at www.rnt.com) or on the Client & Customer-Only Sites) may contain certain forward-looking statements, which are subject to risks and uncertainties and speak only as of the date on which they are made. The words “believe,” “expect,” “anticipate,” “optimistic,” “intend,” “aim,” “will” or similar expressions are intended to identify forward-looking statements. You are cautioned not to place undue reliance on these forward-looking statements. Any dated information is published as of its date only. Dated and forward-looking statements speak only as of the date on which they are made. We undertake no obligation to update or revise any dated or forward-looking statements.

R&T’s Marks

R&T®, Reich & Tang®, Demand Deposit Marketplace®, DDM®, DepositView® and RTID® are registered marks of Reich & Tang Deposit Networks, LLC. TBS Verify® is a registered mark of Total Deposit Solutions, LLC. RNTSSM, Certificate of Deposit MarketplaceSM, R&T FusionSM and Fusion by R&TSM are pending marks of Reich & Tang Deposit Networks, LLC. IDEASM is an unregistered service mark of Reich & Tang Deposit Networks, LLC.

Changes to Legal Disclosures

We may change or replace these Legal Disclosures from time to time in our sole discretion. All changes are effective immediately when we post or provide them, and apply thereafter.

Any Questions?

If you have any questions regarding these Legal Disclosures, please email us at info@rnt.com or at: R&T Deposit Networks, LLC (d/b/a R&T Deposit Solutions), 1370 Broadway, 17th Floor, New York, NY 10018, Attention: Executive Vice President, General Counsel.

Copyright © 2024 Reich & Tang Deposit Networks, LLC (d/b/a R&T Deposit Solutions). All rights reserved.

  1. If a sending institution offers its customers the DDM program with the IDEASM feature, its customers cannot exclude (or opt-out of) any receiving institutions in that program. ↩︎