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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

Fintech-Bank Lending Partnerships: 8 Key Issues

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

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

New York Finalizes Commercial Financing Disclosure Regulations

On February 1, 2023, the New York State Department of Financial Services (DFS) adopted final regulations relating to New York’s Commercial Finance Disclosure Law (CFDL), which requires providers of commercial financing,...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

California Finalizes Commercial Financing Disclosure Regulations

On June 9, 2022, the California Office of Administrative Law (OAL) approved the California Department of Financial Protection and Innovation’s (DFPI) final regulations requiring providers of commercial financing, including...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

Treasury Department’s FSOC Acknowledges Climate Change as Threat to Financial Stability

In This Issue. The Treasury Department’s Financial Stability Oversight Council (FSOC) issued a report acknowledging climate change as threat to financial stability; Federal Reserve Governor Michelle Bowman advocates for...more

OCC Grants National Trust Bank Charter to Third Cryptocurrency Firm

In This Issue. The Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval to a third cryptocurrency firm chartering a national trust bank; the Consumer Financial Protection Bureau (CFPB)...more

SEC Raises Concerns About Misleading ESG Practices, Highlights Potential Violations

In This Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert raising concerns about misleading Environmental, Social, and Governance (ESG) disclosures by investment firms; the...more

SBA and Treasury Department Issue New Guidance on PPP

In this Issue. The Office of the Comptroller of the Currency (OCC) issued guidance on its authority to charter limited purpose trust companies, raising the possibility that a limited purpose national bank could be organized...more

CFPB Affirms Regulation Z Does Not Apply To Non-Recourse Earned Wage Access

Recently, the Consumer Financial Protection Bureau (CFPB) issued an order accepting into the CFPB’s compliance assistance sandbox an earned wage access (EWA) program where participating employees are not obligated to repay...more

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