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
4/8/2025
/ Banks ,
Bitcoin ,
Blockchain ,
Distributed Ledger Technology (DLT) ,
Ethereum ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Investment ,
Regulatory Requirements ,
Risk Management ,
Securities Tokens ,
Smart Contracts
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
4/3/2025
/ Banking Sector ,
Community Reinvestment Act ,
Deregulation ,
Equal Access to Credit ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
OCC ,
Proposed Rules ,
Regulatory Agencies ,
Regulatory Oversight ,
Regulatory Reform ,
Rescission
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
4/1/2025
/ Banks ,
Consumer Financial Products ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Guidance ,
OCC ,
Regulatory Oversight
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
2/27/2025
/ Agribusiness ,
Agricultural Land ,
Capital Requirements ,
Community Banks ,
Equal Access to Credit ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
Regulatory Agenda ,
Regulatory Requirements ,
Rural Areas ,
Small Business
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
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
11/20/2024
/ Bank Deposits ,
Comment Period ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
NPRM ,
Proposed Rules ,
Public Comment ,
Recordkeeping Requirements ,
Third-Party
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
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
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
10/7/2024
/ Bank Deposits ,
Comment Period ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nonbank Firms ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Recordkeeping Requirements ,
Regulatory Agenda ,
Third-Party
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
10/4/2024
/ Bankruptcy Code ,
Banks ,
Commercial Bankruptcy ,
Consumer Financial Products ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Recordkeeping Requirements ,
Risk Management
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
9/19/2024
/ Banks ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
Recordkeeping Requirements ,
Regulatory Agenda ,
Third-Party
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
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
“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
“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
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
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
7/29/2024
/ AML/CFT ,
Anti-Money Laundering ,
Banks ,
Consumer Financial Products ,
Customer Due Diligence (CDD) ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Joint Statements ,
OCC ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Third-Party Relationships