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Ballard Spahr LLP

FDIC Issues Notice of Proposed Regulations for Enhanced Recordkeeping for Third-Party Custodial Accounts

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On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more

Alston & Bird

FDIC Proposes Rule to Establish Custodial Account Recordkeeping Requirements

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Our Financial Services Team studies the Federal Deposit Insurance Corporation’s plans to require insured depository institutions (IDIs) to keep specific records so that they know the actual owner of deposits placed by...more

Mayer Brown

FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

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On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more

BCLP

Synapse Failure Spurs FDIC To Specify Record Keeping for Bank Sponsored Fintechs

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The Federal Deposit Insurance Corporation (“FDIC”) proposed in its Notice of Proposed Rulemaking (“NPR”) that insured IDIs keep records of individual accounts that are typically held in pooled custodial accounts that support...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

Perkins Coie on

The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Fenwick & West LLP

FDIC Proposes More Oversight on Custodial Deposit Accounts

Fenwick & West LLP on

On September 17, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would significantly impact the risk management and oversight requirements for bank-fintech arrangements. This proposal comes in...more

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

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The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more

Nelson Mullins Riley & Scarborough LLP

FDIC Reemphasizes Focus on FinTech Partnerships and Account Reconciliation

In what should come as no surprise to FinTech sponsor banks, the FDIC is reemphasizing the need to maintain control over synthetic account ledgers in the wake of the Synapse collapse. On September 17, the FDIC's rulemaking...more

Venable LLP

New Year, New Signs - FDIC Amends Deposit Insurance Sign and Advertising Regulations

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After an intense 2023 rulemaking, supervisory, and enforcement cycle for the federal banking agencies, the FDIC issued a final rule on FDIC official signs and advertising requirements right before the new year. The rule comes...more

Goodwin

FAQs About US Bank Failure

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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

Morgan Lewis - All Things FinReg

Increased Scrutiny of Uninsured Deposits Continues: FDIC Reminds IDIs of Uninsured Deposit Reporting Obligations

The Federal Deposit Insurance Corporation (FDIC) continued the focus shown over the last several months, and especially since the March 2023 failure of Silicon Valley Bank (SVB) and associated events, by the federal banking...more

Orrick, Herrington & Sutcliffe LLP

FDIC tells three companies to stop claims about deposit insurance

On June 15, the FDIC sent letters ordering three companies and certain of their officers to cease and desist from using the agency’s logo and making false and misleading statements about FDIC deposit insurance. The companies...more

McGlinchey Stafford

FDIC Issues Overview of Deposit Insurance System

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In response to the recent bank failures, on May 1, 2023, the Federal Deposit Insurance Corporation (FDIC) released a report titled “Options for Deposit Insurance Reform” (Report). The Report provides a comprehensive overview...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2023

FDIC Announces Special Assessments to Recover Losses from Recent Bank Failures The FDIC has issued a proposed rule that would impose special assessments to recover the loss to the Deposit Insurance Fund (Fund) arising from...more

Troutman Pepper

FDIC Proposes Special Assessments to Recover Cost of Protecting Uninsured Depositors Amidst Bank Closures

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Today, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking that would impose special assessments to recover losses to the Deposit Insurance Fund (DIF) arising from the FDIC’s protection...more

Kilpatrick

Regulators Offer Candid Assessment of the Root Causes for SVB and Signature Failures

Kilpatrick on

A toxic combination of poor risk management and poor regulatory supervision proved fatal for Silicon Valley Bank (“SVB”) and Signature Bank (“Signature”), according to a series of reports released on April 28, 2023 by federal...more

Foodman CPAs & Advisors

Crypto Asset Related Activities Assessed By The FDIC

On 4/5/23, the FDIC released its 2023 Spring Consumer Compliance Supervisory Highlights. The purpose of the Supervisory highlights is to provide an overview of consumer compliance issues identified through the FDIC’s...more

Troutman Pepper

FDIC Recommends Deposit Insurance Reforms to Better Protect Businesses

Troutman Pepper on

On May 1, the Federal Deposit Insurance Corporation (FDIC) released a report titled Options for Deposit Insurance Reforms, which outlines three options to reform the nation's deposit insurance system. The three options...more

Goodwin

FDIC Pass-Through Coverage

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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

Goodwin

First Republic Bank FAQ

Goodwin on

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

Goodwin

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

Goodwin on

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

Goodwin

Silicon Valley Bank FAQ

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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

Morgan Lewis

Common Cash Management Practices and Associated Protections and Risks

Morgan Lewis on

In the wake of the Silicon Valley Bank and Signature Bank defaults, it is important for bank customers to understand the common cash management options and accounts available in financial institutions as well as their...more

Cadwalader, Wickersham & Taft LLP

FDIC Vice Chair Hill Speaks on Recent Bank Failures

Federal Deposit Insurance Corporation (“FDIC”) Vice Chair Travis Hill gave a speech earlier this week, titled “Recent Bank Failures and the Path Ahead,” at the Bipartisan Policy Center. The speech appears to be Vice Chair...more

Goodwin

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

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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

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