Introduction - On 29 January 2024, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPR) regarding its review of Bank Merger Act (BMA) applications. The NPR was released immediately...more
On Friday 28 April 2023, the Board of Governors of the Federal Reserve System (the FRB) and the Federal Deposit Insurance Corporation (the FDIC) each released a report regarding a recent bank failure. The FRB report covered...more
INTRODUCTION - On 24 January 2023, the Board of Governors of the Federal Reserve System (the FRB) announced it entered into a consent order (Consent Order) with a member bank imposing an approximately US$2.3 million civil...more
On 27 January 2023, the Board of Governors of the Federal Reserve System (the FRB) issued a policy statement (the Policy Statement) that limits state member banks to the activities which are either permissible for national...more
COVID-19 and the resulting economic downturn are expected to strain the U.S. banking system at a time when banks are grappling with how to modernize their products and services and keep pace with technological innovation....more
1. Q. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) implements the disbursement of $1,200 payments of COVID-19 stimulus funds to millions of Americans. How will the current payment system address the...more
The COVID-19 pandemic presents extraordinary and unique challenges for financial institutions. Banks provide critical financial services to the public and are an integral part of the financial life of most Americans. Unlike...more
Innovation and rapid change are permeating financial services. But amidst those trends, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) recently took action aimed at maintaining the status quo....more
Brokered deposits is a hot topic once again. On December 19, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) published an advance notice of proposed rulemaking and request for comment on possible updates to its...more
A serious regulatory issue can derail a bank merger or acquisition. Sometimes a bank will begin a transaction with a known, pre-existing regulatory issue, and other times an unanticipated regulatory issue develops during the...more
Some bankers view the rapid rise of “fintech” as an existential threat to traditional banks, especially community banks. But while fintech surely is changing financial services, it is also creating new opportunities for...more