On October 24, FDIC announced a proposed rule to implement the Fair Hiring in Banking Act (FHB Act). The proposed rule amends 2 C.F.R. part 303, subpart L, and part 308, subpart M. The Federal Deposit Insurance Act (FDI Act)...more
The FDIC has proposed guidelines that would establish corporate governance and risk management expectations for FDIC-regulated banks with $10 billion or more in total assets. The FDIC is doing so in a rulemaking under its...more
Nine Republican AGs, led by Oklahoma AG Gentner Drummond, wrote a letter to the FDIC criticizing its proposed rule that would impose a special assessment on certain banking institutions to recoup the losses to the Deposit...more
A lot of ink has been spilled in the last 72 hours regarding the historic developments involving Silicon Valley Bank and Signature Bank. Our quick summary of the facts and law is below. Cadwalader will continue to monitor...more
On March 10, 2023, the California Department of Financial Protection and Innovation (DFPI) closed Silicon Valley Bank (SVB). Upon closure, the DFPI appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. The...more
With founders and investors in the Project W community increasingly innovating with and investing in digital assets, we asked Alexandra Barrage, a partner in DWT's Financial Services Practice Group and the leader of Project...more
Effective January 10, 2022, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule (the “Primary Purpose Rule”) that adds a specific business relationship that qualifies under the Primary Purpose Exception...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more
On Monday and Tuesday, PLI held its two-day 25th Annual Consumer Financial Services Institute, which I co-chaired. During the morning session of the first day, I co-moderated two consecutive panel discussions titled “Federal...more
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
Federal Deposit Insurance Corporation (FDIC) changes to its interpretation of Section 19 of the Federal Deposit Insurance Act will affect the hiring practices and affirmative action obligations of the financial institutions...more
In a notice of proposed rulemaking (NPRM), the Federal Deposit Insurance Corporation (FDIC) announced its plan to update its brokered deposits regulations....more
Headlines - FDIC Adopts Final Rule Establishing Community Bank Leverage Ratio Framework OCC Issues Compliance Guidance on Registered Appraisal Management Companies CFPB Announces New Policies to Promote Innovation...more
FDIC Approves 3-Year Phase-In for Adverse Effects on Capital from CECL - The FDIC has approved a final rule that will provide banks with the option to phase in over a three-year period the day-one adverse effects on...more
In this week's newsletter, we provide a snapshot of the principal U.S., European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more
The U.S. Federal Deposit Insurance Corporation issued modification to its Statement of Policy with respect to Section 19 of the Federal Deposit Insurance Act, which (among other things) prohibits persons with convictions for...more
The FDIC issued a notice of proposed rulemaking (the “Proposed Rule”) that would revise the FDIC’s risk-based deposit insurance assessment system to reflect the final Basel III capital rule (the “Final Capital Rule”) adopted...more
On September 12, the Board of Directors of the Federal Deposit Insurance Corporation (FDIC) approved a final rule clarifying that deposits in foreign branches of US banks are not FDIC-insured, even though they can be deposits...more
On February 12, the Federal Deposit Insurance Corporation (“FDIC”) proposed for public comment a rule that would exclude from federal deposit insurance coverage those deposits made at insured U.S. banks that are payable at a...more
A little-noticed provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) has the potential of curtailing significant investments by private equity firms in banks. Section 616(d) of Dodd-Frank...more
The FDIC is currently responding to one of the worst financial crises in the history of the nation’s banking system. Sheila Bair, Chairman of the FDIC, expects that 2010 “will be the high water mark for the banking crisis.”1...more