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
On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more
7/31/2024
/ Banking Sector ,
Comment Period ,
Compliance ,
Federal Bank Regulatory Agencies ,
Financial Institutions ,
FinTech ,
Joint Statements ,
Public Comment ,
Request For Information ,
Risk Assessment ,
Risk Management
The Consumer Financial Protection Bureau (CFPB) released a procedural rule updating its supervisory process for institutions seeking to appeal a compliance rating or an adverse finding. Although the appeals process remains...more
A study in the Finance and Economics Discussion Series (FEDS) by the Federal Reserve Board on consumer lending found that financial technology (FinTech) lenders are able to take advantage of federal preemptions from state...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
Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more
6/9/2023
/ Banking Sector ,
FDIC ,
Federal Reserve ,
Final Guidance ,
Financial Institutions ,
Financial Regulatory Agencies ,
FinTech ,
OCC ,
Proposed Guidance ,
Risk Management ,
Third-Party Relationships ,
Third-Party Service Provider