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Where the F(BO) is the Money? Part 3 – DLT Account Ledgering

This is the final article in our three-part series focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

Federal Banking Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule

On March 28, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (together, the federal banking agencies) announced their intent to rescind the...more

FDIC Turns a New Page on Banks’ Engagement in Crypto-Related Activities

Last Friday, the Federal Deposit Insurance Corporation (FDIC) announced the rescission of Financial Institution Letter (FIL-16-2022) and issued new guidance clarifying the process for FDIC-supervised institutions to engage in...more

Legislation Introduced in the House Aims to Support New and Rural Banks by Easing Regulatory Requirements

On January 16, U.S. Representative Andy Barr (R-KY) introduced H.R. 478, the “Promoting New Bank Formation Act,” which was referred to the Committee on Financial Services. This bill aims to support the establishment and...more

FDIC Acting Chairman Hill Outlines Near-Term Policy Direction

On January 20, Travis Hill became the Acting Chairman of the Federal Deposit Insurance Corporation (FDIC). Following his remarks on FDIC policy issues on January 10 at the American Bankers Association, in his first statement...more

FDIC Extends Comment Period for Proposed Rule on Recordkeeping for Third-Party Deposits

In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

Preparing for the FDIC’s Final Enforceable Guidelines on Corporate Governance and Risk Management: State Nonmember Banks with...

Over one year ago, on October 3, 2023, the Federal Deposit Insurance Corporation (FDIC) proposed supervisory guidelines that would establish standards for corporate governance and risk management for all state non-member...more

FDIC Extends Comment Period for Proposed Changes to Brokered Deposit Regulations

Yesterday, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all...more

FDIC Publishes Proposed Rule on Recordkeeping for Third-Party Deposits, Opens Comment Period

We previously posted on the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies....more

Where the F(BO) is the Money? Part 2 — Adopting the Right Lessons from Synapse

This is the second of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

FDIC Proposes New Rule to Strengthen Recordkeeping for Third-Party Deposits

On September 17, the Federal Deposit Insurance Corporation (FDIC) announced a notice of proposed rulemaking (Proposal) aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

Where the F(BO) Is the Money? Part 1 – Synapse’s Clarion Call for Standards

This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

FDIC’s Brokered Deposit Proposal Expected to Face Industry Pushback

Currently, deposit accounts enabling payment transactions are automatically non-brokered, but the new rule will eliminate this designation, meaning parties relying on the “enabling transactions” exception will have to go...more

Bank Allies Say FDIC Brokered Deposit Plan Reflects Outdated Thinking

“Hot money” – as it was later dubbed – was viewed by skeptics as one of the major causes of the savings and loan crisis of the 1980s....more

FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core

“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more

Turning Back the Clock: FDIC Proposes Significant Changes to 2020 Brokered Deposit Rule

On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s...more

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

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