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
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
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
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
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
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
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
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
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
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