CDARS

CDARS places certificates of deposit across participating banks, potentially expanding aggregate FDIC coverage when ownership and recordkeeping rules are satisfied.

CDARS, short for Certificate of Deposit Account Registry Service, is an IntraFi deposit-placement service that places a customer’s funds into certificates of deposit issued by multiple participating banks. The arrangement can provide access to aggregate FDIC coverage across those banks when each deposit and the supporting records satisfy current insurance rules.

FDIC does not insure CDARS as a service, and IntraFi is not an insured bank. FDIC insurance applies separately to eligible deposits at each issuing network bank.

Key Takeaways

  • CDARS is a proprietary service, not a generic type of federal insurance.
  • The customer works through a relationship institution while network banks issue the underlying CDs.
  • Coverage depends on the customer’s ownership category and aggregate eligible balances at each issuing bank.
  • Pass-through coverage requires accurate account titling, beneficial-ownership records, and ownership interests.
  • Existing deposits held directly or through another intermediary at a network bank must be included in the insurance calculation.
  • Funds can face uninsured exposure before placement, after withdrawal settlement, or when records and program conditions are not satisfied.
  • CD maturity and access terms still apply; network placement does not turn a CD into an on-demand account.

How CDARS Works

The customer enters a deposit-placement arrangement through a participating relationship institution. Under the applicable instructions and agreements:

  1. The relationship institution receives the customer’s placement request and funds.
  2. The service allocates funds among eligible network banks in amounts designed to remain within the standard FDIC insurance maximum.
  3. Each receiving network bank issues a CD obligation.
  4. Custody and subcustody records identify the customer and the CDs held for that customer.
  5. The relationship institution provides consolidated information and processes maturity or withdrawal instructions under the program terms.

The depositor may be able to exclude particular banks from receiving funds. That matters when the depositor already has accounts at a possible receiving bank or is subject to an institutional, legal, or policy restriction.

    flowchart LR
	    A["Depositor"] --> B["Relationship institution"]
	    B --> C["CDARS allocation and custody records"]
	    C --> D["Network bank A issues CD"]
	    C --> E["Network bank B issues CD"]
	    C --> F["Network bank C issues CD"]
	    D --> G["Consolidated customer reporting"]
	    E --> G
	    F --> G

Worked Example: Existing Deposits at a Network Bank

Deposit insurance is calculated by depositor, insured bank, and ownership category. A network placement does not receive a separate category merely because it arrived through CDARS.

Assume a business has a $200,000 network-placed CD and a separate $75,000 deposit in the same business-account category at the same issuing bank.

Balance at the issuing bankAmount
Network-placed CD principal$200,000
Separate direct deposit$75,000
Aggregate before accrued interest$275,000
Amount above a $250,000 standard maximum$25,000

The $25,000 excess could be uninsured, and accrued CD interest can increase that exposure. An allocation intended to remain within the standard maximum would need to exclude that receiving bank or reduce the amount placed there.

This is why a simple “four banks times $250,000 equals $1 million” example is unreliable. Allocation must account for other same-bank balances, accrued interest, ownership category, and changes before maturity.

Pass-Through Insurance and Records

In a custodial arrangement, the FDIC may recognize the customer as the beneficial owner even though an agent or custodian holds the account. FDIC guidance explains that pass-through insurance is not a separate ownership category. Coverage is determined as though the owner held the deposit directly, provided the applicable ownership, disclosure, and recordkeeping requirements are met.

If required records do not identify the beneficial owner and ownership interest, coverage can be calculated differently. In a bank failure, the FDIC may need information from the placement agent or custodian before it can determine coverage and payment.

CDARS vs. Direct Multi-Bank CDs vs. ICS

FeatureCDARSDirect CDs at several banksICS
Deposit typeCDsCDsDemand deposit or money market deposit accounts under service terms
Bank relationshipsOne relationship institution plus network issuersSeparate direct relationshipsOne relationship institution plus network banks
MaturityCD terms applyEach CD’s terms applyTransaction-account terms apply
ReportingConsolidated program recordsSeparate bank recordsConsolidated program records
Insurance analysisPer owner, category, and issuing bankPer owner, category, and bankPer owner, category, and receiving bank
Main operational dependencyPlacement and custody recordsCustomer’s own recordsPlacement and custody records

ICS is a separate IntraFi service. It should not be described as CDARS merely because both use a bank network.

Reciprocal and One-Way Placements

Some network transactions are reciprocal: the relationship institution places customer funds at other banks and receives matching deposits through the network. Other placements can move funds away without a matching reciprocal amount.

The distinction can affect how a bank reports and manages the funding under brokered- and reciprocal-deposit rules. It does not change the depositor’s need to verify the actual issuing banks, ownership records, and insurance aggregation.

Access, Maturity, and Settlement

CDARS uses CDs, so funds are tied to CD maturities and program instructions. Early access may be unavailable, limited, or subject to the placement agreement and issuing-bank terms. A customer should not assume that all network CDs can be liquidated on demand or sold in a secondary market.

IntraFi disclosures also caution that balances at the relationship institution before placement or after withdrawal settlement can exceed the insurance maximum. The exact timing of placement and withdrawal matters when continuous coverage is required.

Risks and Limitations

  • Aggregation risk: undisclosed same-bank deposits can create an uninsured amount.
  • Recordkeeping risk: incomplete ownership or custody records can delay or change coverage determination.
  • Liquidity risk: CD maturities may not align with an unexpected cash need.
  • Settlement risk: funds can temporarily sit outside the intended network allocation.
  • Rate and fee risk: the offered rate and any program economics may differ from direct alternatives.
  • Program dependency: instructions, custody, statements, and claims rely on several institutions and service providers.
  • Eligibility risk: public entities, fiduciaries, and policy-restricted depositors may have additional legal requirements.

What to Verify

  • relationship institution and each issuing network bank
  • customer ownership category and beneficial owner
  • all other deposits at potential receiving banks
  • principal plus expected accrued interest at each bank
  • placement, custody, and subcustody records
  • rate, term, maturity, and renewal instructions
  • early-access and withdrawal-settlement rules
  • excluded-bank list and process for updating it
  • fees or rate adjustments under the relationship
  • legal or investment-policy authority to use the arrangement

Official and Primary Sources

FAQs

Does CDARS guarantee that every dollar is FDIC-insured?

No. Coverage depends on successful placement at insured banks, ownership category, aggregate same-bank balances, accrued interest, and pass-through recordkeeping requirements. Funds outside those conditions can be uninsured.

Is CDARS itself an FDIC-insured bank?

No. CDARS is an IntraFi service. FDIC insurance applies to eligible deposits issued by participating insured banks, not to the network operator or service name.

Can CDARS funds be withdrawn at any time?

Not necessarily. CDARS places funds in CDs, so maturity and early-access restrictions apply. The deposit-placement agreement and issuing-CD terms determine whether and when funds can be withdrawn.

This article provides general financial education, not personalized banking, investment, tax, legal, accounting, or deposit-insurance advice.

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