Following the 2023 banking turmoil, the Basel Committee on Banking Supervision reviewed more than 100 academic studies and regulatory reports to assess whether structural changes in the system have altered the stability of nonmaturity deposits. Earlier articles summarized the review’s findings on technology and changes to the industry and depositor base. This third and final review summary examines how regulatory or legal changes may have influenced depositor behavior.
The literature finds that legal and regulatory changes have had mixed effects on deposit stability.
For bank leaders, the key question is how quickly uninsured and rate-sensitive deposits could leave under stress.
Questions to consider:
Deposit insurance generally improves deposit stability by reducing incentives to run, according to the literature. Because deposit insurance frameworks don't provide full coverage, the amount of coverage influences depositor stability. Indexing deposit insurance coverage, particularly during times of high inflation, can help preserve its real value and maintain depositor confidence over time.
Post-GFC reforms introduced stricter capital and liquidity requirements. The literature suggests these changes strengthened bank resilience, improved depositor confidence by reducing solvency and liquidity concerns and may have increased demand for retail deposits. During the 2023 regional banking turmoil, deposits flowed to the largest banks, reflecting confidence in their stronger regulatory requirements or perceptions they were too systemically important to be allowed to fail.
Post-GFC reforms mitigated fears of MMF fragility by requiring some funds to invest only in government securities and others to use a floating net asset value. Strong asset growth since then, particularly during the pandemic, suggests these changes may have increased competition for bank deposits, particularly during periods of rising interest rates.
A 2018 statutory change permitted a capped amount of reciprocal deposits to be treated as nonbrokered deposits, leading to significant growth in their use. By distributing deposits across banks and to access additional insurance coverage, reciprocal deposits appear to have enhanced financial stability and helped reduce deposit outflows during the 2023 banking turmoil.
Rules requiring banks to reflect changes in the market value of available-for-sale securities in regulatory capital encouraged them to classify more securities as held-to-maturity. The literature suggests held-to-maturity (HTM) accounting may have masked unrealized losses and reduced market discipline, with Silicon Valley Bank cited as an example.
The Basel Committee finds that legislative and regulatory changes have had mixed effects on deposit stability. Reciprocal deposits, deposit insurance, and capital and liquidity reform appear to have enhanced stability, while reforms related to MMFs and the accounting treatment for HTM securities may have increased deposit competition or obscured underlying risks.
Banks seeking to retain large relationships, reduce uninsured balances, and enhance funding stability should evaluate whether they are making full use of reciprocal deposits. The 21st Century ROAD to Housing Act, enacted on July 11, 2026, further expands this tool by allowing more reciprocal deposits to be considered nonbrokered deposits.
Academic research often shapes how banking risks and policies are understood. IntraFi's Research Briefs for Bank Executives distill relevant research studies into concise, accessible summaries focused on what the findings mean for bank leadership.