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
9/19/2024
/ Banking Sector ,
Banks ,
Comment Period ,
Compliance ,
Deposit Accounts ,
Depository Institutions ,
FBOs ,
FDIC ,
Financial Services Industry ,
FinTech ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements
Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more
The FDIC recently proposed a rule that would substantially change the 2020 final rule on brokered deposits that largely liberalized the FDIC’s framework. The proposed rule would eliminate many of the changes from 2020 and...more
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
5/14/2024
/ Banking Regulators ,
Banking Sector ,
Banks ,
Community Banks ,
Enforcement ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Final Guidance ,
Financial Institutions ,
Joint Policy Statements ,
New Guidance ,
Nonbank Firms ,
OCC ,
Regulatory Oversight ,
Risk Management ,
Third-Party ,
Third-Party Risk
In January 2024, one of the largest U.S. non-bank merchant acquirers announced that it is pursuing a special-purpose bank charter developed by Georgia. Although the “merchant acquirer limited purpose bank” (MALPB) has been a...more
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
1/24/2024
/ Advertising ,
Amended Regulation ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
Digital Communications ,
FDIC ,
Final Rules ,
FinTech ,
Internal Controls ,
Policies and Procedures ,
Signs ,
Third-Party Service Provider
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
On June 16, 2023, the Federal Deposit Insurance Corporation (FDIC) released an update to its Supervisory Guidance on Multiple Re-Presentment NSF Fees (FIL-40-2022) (the "Guidance"), to provide additional guidance for...more