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Federal Deposit Insurance Corporation › Third-Party

The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s.  The FDIC's mission is to maintain... more +
The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s.  The FDIC's mission is to maintain stability and consumer confidence in the United States banking system by insuring deposits, monitoring the health of financial institutions and managing receiverships.  less -
Troutman Pepper

FDIC Proposes New Rule to Strengthen Recordkeeping for Third-Party Deposits

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On September 17, the Federal Deposit Insurance Corporation (FDIC) announced a notice of proposed rulemaking (Proposal) aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

McGlinchey Stafford

Bank Partnerships in an Evolving World

McGlinchey Stafford on

Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

Venable LLP on

It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

Ballard Spahr LLP on

On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more

Sheppard Mullin Richter & Hampton LLP

FDIC Issues Consent Order Against Tennessee Bank

Sheppard Mullin Richter & Hampton LLP on

On January 30, a Tennessee-based community bank entered into a consent order with the Federal Deposit Insurance Corp. following the agency’s allegations that the Bank engaged in unsafe or unsound banking practices relating to...more

Troutman Pepper

FDIC Announces Lineage Bank Consent Order Containing Third-Party Risk Management Program and Fintech Partnership Orders

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The Federal Deposit Insurance Corporation (FDIC) recently announced a consent order with Tennessee-based Lineage Bank containing orders relating to the bank’s third-party risk management program and its financial technology...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Adams and Reese LLP

FDIC Sends Clear Message in Recent Enforcement Action: BaaS/Fintech Partnerships are a High-Risk Compliance Area

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Last month, the Federal Deposit Insurance Corporation (“FDIC”) took action against a bank for alleged unsafe or unsound banking practices. This, in and of itself, is not usual or newsworthy. What is unusual and newsworthy,...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

McGlinchey Stafford on

On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Latham & Watkins LLP

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

Latham & Watkins LLP on

The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Wilson Sonsini Goodrich & Rosati

Guardrails for Bank-Fintech Partnerships: The Federal Banking Agencies Finalize Third-Party Risk Management Expectations

Wilson Sonsini Goodrich & Rosati on

The Board of Governors of the Federal Reserve System (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued the long-awaited...more

Morrison & Foerster LLP

Banking Agencies Issue Joint Third-Party Risk Management Guidance

Morrison & Foerster LLP on

On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more

Jenner & Block

Client Alert: Bank-Fintech Partnerships Update: Banking Agencies Finalize Key Risk Management Guidance

Jenner & Block on

On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more

Katten Muchin Rosenman LLP

Bank/Fin-Tech Agreements: Re-Assessment Required Given New Regulatory Guidance on Third-Party Servicing Agreements

Katten Muchin Rosenman LLP on

On June 6, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Banking Agencies)...more

Buchalter

FDIC, FRB & OCC Issue Interagency Guidance on Third-Party Relationships: Risk Management

Buchalter on

June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more

Ballard Spahr LLP

Federal Agencies Propose Reconsideration of Value Guidance

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A group of federal agencies have proposed reconsideration of value (ROV) guidance for residential real estate valuations. The agencies are the Comptroller of the Currency (OCC), Consumer Financial Protection Bureau (CFPB),...more

Mitratech Holdings, Inc

US Regulators Raise Expectations of Third-Party Risk Management

Mitratech Holdings, Inc on

It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...more

Morgan Lewis - All Things FinReg

The Antitrust Risk of the Federal Banking Agencies’ Proposed Risk Management Guidance

Morgan Lewis - All Things FinReg on

As highlighted previously, three federal banking agencies (the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency) recently issued proposed risk management...more

Baker Donelson

Proposed Third-Party Relationships Guidance Comment Period Extended

Baker Donelson on

On July 13, 2021, the Board of Governors of the Federal Reserve (the "Fed"), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (the OCC, collectively referred to herein with...more

Baker Donelson

New Proposed Guidance on Third-Party Relationships

Baker Donelson on

On July 13, 2021, the Board of Governors of the Federal Reserve (the "Fed"), the Federal Deposit Insurance Corporation (the FDIC) and the Office of the Comptroller of the Currency (the OCC), with the Fed and the FDIC...more

Perkins Coie

Fintech Week in Review - April 2021 #2

Perkins Coie on

FDIC Consumer Compliance Supervisory Highlights Fair Lending Risks - The Federal Deposit Insurance Corporation (FDIC) has issued the March 2021 edition of its Consumer Compliance Supervisory Highlights. The publication was...more

Morrison & Foerster LLP

FDIC Brokered Deposits Final Rule: Key Aspects For Broker Dealers

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On January 22, 2021, the Federal Deposit Insurance Corporation (“FDIC”) published its final rule (“Final Rule”) revising and modernizing its regulations related to brokered deposits and the interest rate restrictions that...more

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