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Legal Alert
January 31, 2024

Bank Term Funding Program to Expire on March 11

Authors and Contacts

Tyler A. O'Reilly

Mathew P. Barry

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The Federal Reserve’s Bank Term Funding Program (BTFP) will sunset as planned on March 11, ending a program that helped calm the markets after last year’s collapses of Silicon Valley Bank and Signature Bank threatened a broader financial crisis.

Motivated by concerns of potential spillover effects following these social media-fueled bank runs, the Federal Reserve created the BTFP to provide an additional source of liquidity for eligible depository institutions to meet the needs of their depositors.

In a news release on the BTFP issued January 24, the Federal Reserve confirmed the program will continue to issue loans until March 11; then, banks and other depository institutions will have access to the discount window to meet liquidity needs during times of stress.

The Federal Reserve also announced a rate hike on new loans for the remaining BTFP term, saying “the interest rate applicable to new BTFP loans has been adjusted such that the rate on new loans extended from now through program expiration will be no lower than the interest rate on reserve balances in effect on the day the loan is made.”

This pricing change was effective immediately, closing an arbitrage opportunity that emerged for U.S. banks. Before the change, pricing was tied to market expectations for benchmark interest rates average over the next year. As investors started to price in a series of rate cuts for 2024, borrowing costs for BTFP loans dipped below the interest payable on overnight deposits.

All other terms of the program are unchanged.

The Harris Beach Financial Institutions and Capital Markets Team is watching this issue and other related matters. If you have questions for our banking lawyers, please reach out to attorney Tyler A. O’Reilly at (585) 419-8634 and toreilly@harrisbeachmurtha.com, attorney Mathew P. Barry at (518) 701-2768 and mbarry@harrisbeachmurtha.com, or the Harris Beach attorney with whom you most frequently work.

This alert is not a substitute for advice of counsel on specific legal issues.

Harris Beach has offices throughout New York state, including Albany, Buffalo, Ithaca, Long Island, New York City, Rochester, Saratoga Springs, Syracuse and White Plains, as well as Washington D.C., New Haven, Connecticut and Newark, New Jersey.

Authors and Contacts

Mathew Barry

Mathew P. Barry

Member
Tyler O'reilly

Tyler A. O'Reilly

Member

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Insights

Bank Term Funding Program to Expire on March 11

Capabilities
People
Harris Beach Murtha Attorneys at Law
Legal Alert
January 31, 2024

Bank Term Funding Program to Expire on March 11

Insight

The Federal Reserve’s Bank Term Funding Program (BTFP) will sunset as planned on March 11, ending a program that helped calm the markets after last year’s collapses of Silicon Valley Bank and Signature Bank threatened a broader financial crisis.

Motivated by concerns of potential spillover effects following these social media-fueled bank runs, the Federal Reserve created the BTFP to provide an additional source of liquidity for eligible depository institutions to meet the needs of their depositors.

In a news release on the BTFP issued January 24, the Federal Reserve confirmed the program will continue to issue loans until March 11; then, banks and other depository institutions will have access to the discount window to meet liquidity needs during times of stress.

The Federal Reserve also announced a rate hike on new loans for the remaining BTFP term, saying “the interest rate applicable to new BTFP loans has been adjusted such that the rate on new loans extended from now through program expiration will be no lower than the interest rate on reserve balances in effect on the day the loan is made.”

This pricing change was effective immediately, closing an arbitrage opportunity that emerged for U.S. banks. Before the change, pricing was tied to market expectations for benchmark interest rates average over the next year. As investors started to price in a series of rate cuts for 2024, borrowing costs for BTFP loans dipped below the interest payable on overnight deposits.

All other terms of the program are unchanged.

The Harris Beach Financial Institutions and Capital Markets Team is watching this issue and other related matters. If you have questions for our banking lawyers, please reach out to attorney Tyler A. O’Reilly at (585) 419-8634 and toreilly@harrisbeachmurtha.com, attorney Mathew P. Barry at (518) 701-2768 and mbarry@harrisbeachmurtha.com, or the Harris Beach attorney with whom you most frequently work.

This alert is not a substitute for advice of counsel on specific legal issues.

Harris Beach has offices throughout New York state, including Albany, Buffalo, Ithaca, Long Island, New York City, Rochester, Saratoga Springs, Syracuse and White Plains, as well as Washington D.C., New Haven, Connecticut and Newark, New Jersey.

Authors

Mathew P. Barry

Member
(518) 701-2768
mbarry@harrisbeachmurtha.com

Tyler A. O'Reilly

Member
(585) 419-8634
toreilly@harrisbeachmurtha.com
Attorney Advertising. Prior results do not guarantee a similar outcome. © 2026 Harris Beach Murtha Cullina PLLC
Content current as of October 6, 2026 8:05 am