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Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

FDIC Proposes Overhaul to Brokered Deposit Classification Rules; Significant Impact to Banking as a Service (BaaS) Industry

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would make significant revisions to the FDIC’s regulations implementing the provisions of Section 29 of the Federal Deposit...more

FDIC Approves ILC With Traditional Bank Business Model (But Don’t Rush To Submit Your Application Just Yet)

An industrial bank or industrial loan company (each, an ILC) charter can be an attractive option for a financial technology company (fintech) or other company seeking to enter the banking space. In June 2024, the Federal...more

FinCEN (and SEC) Propose New Customer Identification Program Rule With Minimal Expected Impact on Private Fund Sponsors

On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more

Dos and Don'ts of Interacting with Bank Regulators

Supervision is a daily fact of life for bank boards and management. Below, we offer strategies for how both board members and members of management can ensure that the supervisory process goes as smoothly as possible....more

FinCEN Proposes AML Program Rule for Investment Advisers

The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more

FAQs About US Bank Failure

Deposit Insurance - Are the deposits at my bank FDIC-insured? Deposits held at FDIC-insured depository institutions are insured up to $250,000 per depositor for deposits held in the same “right and capacity.”...more

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

FDIC Proposes Guidelines Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total...

On October 3, 2023, the Federal Deposit Insurance Corporation (FDIC) approved proposed guidelines establishing standards for corporate governance and risk management for covered institutions with total assets of $10 billion...more

Banking Agencies Finalize Community Reinvestment Act Rules

On October 24, 2023, the Board of Governors of the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the Agencies) approved long-awaited final...more

FinCEN Publishes Notice and Proposed Rule Related to CTA Beneficial Ownership Information System

Why it matters: Information gathered and maintained by FinCEN under the CTA will be exempt from notification and record access requirements, and individuals will not be permitted to contest the contents of a report if, for...more

Federal Banking Agencies Propose Basel III Endgame Capital Rules

On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more

FDIC Pass-Through Coverage

Since the failure of Silicon Valley Bank in March of this year, there has been a renewed focus on Federal Deposit Insurance Corporation (FDIC) deposit insurance coverage, including arrangements that provide so-called...more

First Republic Bank FAQ

This FAQ was last updated at 3 pm EST on May 1, 2023. This is an evolving situation, and we will update this FAQ as more information becomes available. What happened with First Republic Bank? On May 1, 2023, First...more

FAQ About Recent Bank Failures in the US (Updated April 28, 2023)

Are the deposits at my bank FDIC-insured? Deposits held at FDIC-insured depository institutions are insured up to $250,000 per depositor for deposits held in the same “right and capacity” (see below)....more

Silicon Valley Bank FAQ

I had deposits at Silicon Valley Bank (SVB) that were assumed by First Citizens Bank. Are my deposits fully insured? Deposits at First Citizens are insured up to the standard maximum deposit insurance amount, which is...more

FAQ About Recent Bank Failures in the US (Updated April 12)

I had deposits at Silicon Valley Bank (SVB) that were assumed by First Citizens. Are my deposits fully insured? Deposits at First Citizens are insured up to the standard maximum deposit insurance amount, which is $250,000...more

Turbulent Banking Sector Renews Interest in Cash Management and Investment Policies

Silicon Valley Bank was a leading bank for the tech and life science sectors and for many of the venture capitalists who invest in those sectors. The bank’s abrupt disclosure on Wednesday, March 8, of significant losses on...more

FAQ About Recent Bank Failures in the US

What actions did the US government take on Sunday with respect to Silicon Valley Bank (SVB) and Signature Bank? On Sunday, March 12, the FDIC, the Federal Reserve, and the US Treasury Department announced that the US...more

How should I be thinking about my cash management options in light of recent events?

Consider multiple bank relationships. Consider putting in place one or more additional banking relationships. Consider banking with an institution that maintains excess deposit insurance. Massachusetts-chartered savings...more

FAQ About the Silicon Valley Bank Situation in the US

What happened to Silicon Valley Bank (SVB) on March 10? ..The California Department of Financial Protection and Innovation took possession of SVB on Friday morning, March 10, 2023, and appointed the Federal Deposit...more

FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On September 29, 2022, FinCEN issued a final rule (published in the Federal Register the next day) under the CTA requiring each “reporting company” (which includes both domestic and foreign entities that are formed or...more

FinCEN Proposes Rules Implementing Corporate Ownership Requirements Under Corporate Transparency Act to Fill Gaps in U.S....

WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336...more

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