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An Abundance of Riches: Do Increasing Deposits Mean Less for Borrowers?

Attracting deposits for banks isn’t always an easy thing, witness the use of brokered deposits. But these days, since the beginning of the pandemic, deposits in banks have jumped to over $15.8 trillion in the first quarter,...more

6/25/2020  /  Banking Sector , Banks , Borrowers , Lenders , Loans

COVID-19: Its Impact on Banking, Fintech, and Payments: FAQs

1. Q. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) implements the disbursement of $1,200 payments of COVID-19 stimulus funds to millions of Americans. How will the current payment system address the...more

Volcker Revamp Viewed Vividly: What You Need to Know About the Agencies’ Proposal to Modify Restrictions on Covered Funds

On January 30, 2020, the Board of Governors of the Federal Reserve System, the Board of Directors of the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange...more

FDIC Proposes Brokered Deposit Relief

On December 12, 2019, the Federal Deposit Insurance Corporation (FDIC) released proposed revisions to its brokered deposit regulation that will, if finalized in their proposed form, provide long sought relief for insured...more

OCC and FDIC Propose Rules to Confirm “Valid-When-Made” Doctrine

Over the last two days, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (together, the “Agencies”) each issued a proposed rule (collectively, the “Proposed Rules”)...more

11/25/2019  /  FDIC , Lenders , OCC , Proposed Rules

OCC and FDIC Ease “Volcker Rule” Restrictions on Proprietary Trading: SEC, CFTC, and Federal Reserve Expected to Follow Suit

On August 20, 2019, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) approved amendments to regulations implementing Section 13 of the Bank...more

The OCC’s New Fintech Bank Charter - What You Need to Know

Part 1: Federal Regulatory Implications - On July 31, 2018, the Office of the Comptroller of the Currency (“OCC”) announced that it will begin accepting applications for national bank charters from nondepository financial...more

In the Weeds: Momentum Builds in Congress to Lift Federal Restrictions on Marijuana

Forty-six states currently have marijuana legalization laws. Twenty-nine states and the District of Columbia have legalized medical marijuana, while seventeen states have allowed access to certain strains for some medical...more

OCC Explores Special Purpose National Bank Charter for Fintech Companies

On December 2, 2016, the Office of the Comptroller of the Currency (“OCC”) announced its plans to move forward with a proposal to consider applications from financial technology (“fintech”) companies to receive charters as...more

FinCEN Looks to Financial Institutions to File SARs Regarding Cyber-Events

On October 25, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory (the “Advisory”) explaining the obligations a “financial institution” might have under the Bank Secrecy Act (“BSA”) regarding...more

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