This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more
This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
5/7/2025
/ Acquisitions ,
Bank Holding Company ,
Bank Holding Company Act ,
Banking Sector ,
Banks ,
Capital Requirements ,
Community Reinvestment Act ,
Controlling Stockholders ,
Depository Institutions ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Investors ,
National Bank Charters ,
Shareholders ,
Supervision
This is the first in a series of articles in our "So, You Want to Be a Bank?" series.
More than 1,000 new banks were formed in the eight years before the Great Recession began in 2008. In comparison, the past 15 years...more
5/1/2025
/ Acquisitions ,
Banks ,
Business Formation ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
Lenders ,
Mortgages ,
National Bank Charters ,
Regulatory Reform
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
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
1/10/2024
/ Banking Crisis ,
Banks ,
Contract Terms ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Financial Institutions ,
Investment Management ,
Loans ,
Money Market Funds ,
Mutual Funds ,
Portfolio Managers ,
Receivership ,
Silicon Valley ,
State Charters ,
Systemic Risk Buffer ,
Transfer Agents
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
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
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
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
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
4/13/2023
/ Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Foreign Branch Offices ,
Offshore Banks ,
Receivership ,
Relief Measures ,
Silicon Valley ,
U.S. Treasury
Partnerships between financial technology companies (fintechs) and banks have revolutionized the financial services landscape. The convergence of technology and banking has resulted in financial products and services being...more
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
3/17/2023
/ Asset Management ,
Banking Sector ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Insolvency ,
Receivership ,
Relief Measures ,
Silicon Valley
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
3/15/2023
/ Banking Sector ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Insolvency ,
Loans ,
Receivership ,
Relief Measures ,
Silicon Valley ,
U.S. Treasury
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
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
In this Issue. The Office of the Comptroller of the Currency (OCC) delayed publication of the “fair access” rule finalized late in the Trump Administration; the OCC also announced the availability of the 2021 list of bank...more
2/9/2021
/ Banking Sector ,
Banks ,
California Consumer Financial Protection Law (CCFPL) ,
Community Reinvestment Act ,
Debt Collection ,
Debtors ,
Delays ,
Department of Financial Protection and Innovation (DFPI) ,
Fair Access to Credit ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Paycheck Protection Program (PPP) ,
Proposed Rules ,
SBA ,
Securities Regulation ,
Trump Administration ,
Unfair or Deceptive Trade Practices
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more
11/12/2020
/ Banking Sector ,
Banks ,
Blockchain ,
Board of Directors ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Debt Settlement Services ,
Disclosure ,
Diversity ,
Enforcement Actions ,
FDCPA ,
FDIC ,
Federal Bank Regulatory Agencies ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Geographic Targeting Order ,
Interest Rates ,
Joint Statements ,
Libor ,
Loans ,
New Guidance ,
New Rules ,
No-Action Letters ,
OCC ,
Payday Loans ,
PayPal ,
Publicly-Traded Companies ,
Real Estate Transactions ,
Shareholders ,
Small Dollar Lenders ,
Student Loans ,
Telemarketing Sales Rule ,
Title Insurance
In the News. The Securities and Exchange Commission (SEC) adopted final rules to update and expand the statistical disclosures that bank and savings and loan registrants must provide to investors for the first time in 30...more
9/17/2020
/ Accredited Investors ,
Amended Rules ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
Brokers ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Crowdfunding ,
Data Collection ,
Deposit Insurance ,
Disclosure Requirements ,
Disparate Impact ,
Dodd-Frank ,
Extensions ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Filing Fees ,
Final Rules ,
Financial Reporting ,
Financial Services Industry ,
FinCEN ,
Flood Insurance ,
HUD ,
Interim Final Rules (IFR) ,
Investors ,
Leverage Ratio ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Public Comment ,
Qualified Institutional Buyers ,
Relief Measures ,
Savings and Loan Companies ,
Section 1071 ,
Securities and Exchange Commission (SEC) ,
Small Business ,
Temporary Regulations ,
Time Extensions
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
8/28/2020
/ Abuse of Discretion ,
Alternative Reference Rates Committee (ARRC) ,
Appeals ,
Arbitrary and Capricious ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
Best Practices ,
CARD Act ,
Carried Interest ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Credit Discrimination ,
Delays ,
Depository Institutions ,
Due Diligence ,
Enforcement Actions ,
Fannie Mae ,
FDIC ,
Federal Deposit Insurance Act ,
Fees ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Freddie Mac ,
GSE ,
Interim Final Rules (IFR) ,
Joint Statements ,
Libor ,
Loan Forgiveness ,
Loans ,
OCC ,
Paycheck Protection Program (PPP) ,
Policy Statement ,
Predatory Lending ,
Proposed Regulation ,
Public Comment ,
Refinancing ,
Regulatory Requirements ,
Request For Information ,
Rulemaking Process ,
SBA ,
Small Business ,
Small Business Loans
In the News. The Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking to create a new category of “seasoned” qualified mortgages; the Securities and Exchange Commission’s (SEC) Office of...more
8/21/2020
/ 401k ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Regulators ,
Banking Sector ,
Banks ,
Bitcoin ,
Broker-Dealer ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Defined Contribution Plans ,
Department of Labor (DOL) ,
EBSA ,
Employee Retirement Income Security Act (ERISA) ,
Enforcement Actions ,
Enforcement Guidance ,
Fannie Mae ,
Fees ,
Financial Institutions ,
Financial Services Industry ,
Freddie Mac ,
Interim Final Rules (IFR) ,
Investment Adviser ,
Joint Statements ,
Lifetime Income Disclosures ,
Mortgages ,
Notice of Proposed Rulemaking (NOPR) ,
OCIE ,
Pension Benefits ,
Pensions ,
Plan Administrators ,
Refinancing ,
Retirement Plan ,
Retirement Plan Providers ,
Risk Alert ,
Securities and Exchange Commission (SEC)
In the News. The Securities and Exchange Commission (SEC) proposed modifying the disclosure framework for mutual funds and exchange-traded funds (funds), which would create a new layered disclosure regime that attempts to...more
8/14/2020
/ Alternative Reference Rates Committee (ARRC) ,
Annual Reports ,
Banking Sector ,
Banks ,
Board of Governors ,
Borrowers ,
Business Development Companies ,
Capital Requirements ,
Closed-End Funds ,
Comment Period ,
Coronavirus/COVID-19 ,
Disclosure Requirements ,
Enforcement Actions ,
Excessive Fees ,
Exchange-Traded Products ,
Federal Reserve ,
Fees ,
Financial Services Industry ,
Form N-1A ,
Interim Final Rules (IFR) ,
Investment Adviser ,
Investment Companies ,
Investment Company Act of 1940 ,
Investment Funds ,
Investment Management ,
Investors ,
Lenders ,
Libor ,
Loan Forgiveness ,
Municipal Liquidity Facility (MLF) ,
Mutual Funds ,
OCC ,
Paycheck Protection Program (PPP) ,
Public Comment ,
Registered Funds ,
Retail Investors ,
Rule 30e-3 ,
SBA ,
SEC Advertising Rule ,
Section 36(b) ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Shareholders
In This Issue. The Securities and Exchange Commission (SEC) finalized amendments to its proxy solicitation rules that will modify the practices of proxy advisory firms, providing them with greater transparency and...more
8/3/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Alternative Reference Rates Committee (ARRC) ,
Banking Sector ,
Banks ,
Borrowers ,
Broker-Dealer ,
CFTC ,
Confidential Supervisory Information ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Discrimination ,
Criminal Records ,
Cross-Border ,
Cryptocurrency ,
Disclosure Requirements ,
Dodd-Frank ,
Emergency Lending ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Records ,
Financial Services Industry ,
FinTech ,
FOIA ,
Form CRS ,
Freedom of Information ,
Lenders ,
Liquidation ,
Loan Applications ,
Loan Forgiveness ,
OCC ,
Paycheck Protection Program (PPP) ,
Proxy Advisory Firms ,
Proxy Season ,
Proxy Solicitations ,
Proxy Voting ,
SBA ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Swaps ,
Virtual Currency
On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter confirming that national banks and federal savings associations (banks) may provide cryptocurrency custody services to...more
In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope, creating public health and humanitarian challenges worldwide. Global economies are also being impacted. Federal...more
3/12/2020
/ Banking Sector ,
Banks ,
Business Continuity Plans ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Crisis Management ,
Disclosure Requirements ,
Exemptive Relief ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Foreign Banks ,
Foreign Investment ,
Infectious Diseases ,
Investment Management ,
New Guidance ,
OCC ,
Proposed Rules ,
Public Health ,
Risk Management ,
Securities and Exchange Commission (SEC)
In This Issue. The Federal Deposit Insurance Corporation (FDIC) published new procedures for federal deposit insurance applications from applicants that are not traditional community banks; federal banking regulators released...more
2/13/2020
/ Applications ,
Banking Sector ,
Banks ,
BlackRock ,
Borrowers ,
Community Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Deposit Insurance ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Fraud ,
Financial Services Industry ,
Insurance Industry ,
Interest Rates ,
Investment Funds ,
Investors ,
Lenders ,
New Guidance ,
Non-Bank Lenders ,
Payday Loans ,
Publicly-Traded Companies ,
State Attorneys General ,
State Street ,
Stress Tests ,
Truth in Lending Act (TILA)