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Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

FDIC Proposes Overhaul to Brokered Deposit Classification Rules; Significant Impact to Banking as a Service (BaaS) Industry

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would make significant revisions to the FDIC’s regulations implementing the provisions of Section 29 of the Federal Deposit...more

CTA Update: FinCEN Clarifies BOI Reporting Requirements for Dissolved Reporting Companies

On July 8, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released new and updated Frequently Asked Questions (FAQs) that clarify FinCEN’s final rules regarding beneficial ownership...more

FDIC Approves ILC With Traditional Bank Business Model (But Don’t Rush To Submit Your Application Just Yet)

An industrial bank or industrial loan company (each, an ILC) charter can be an attractive option for a financial technology company (fintech) or other company seeking to enter the banking space. In June 2024, the Federal...more

New York Governor Signs LLC Transparency Act

On December 22, 2023, New York Gov. Kathy Hochul signed the LLC Transparency Act (as amended, the Act). The Act, modeled after the federal Corporate Transparency Act (CTA), aims to enhance the ability of the State of New York...more

Dos and Don'ts of Interacting with Bank Regulators

Supervision is a daily fact of life for bank boards and management. Below, we offer strategies for how both board members and members of management can ensure that the supervisory process goes as smoothly as possible....more

FAQs About US Bank Failure

Deposit Insurance - Are the deposits at my bank FDIC-insured? Deposits held at FDIC-insured depository institutions are insured up to $250,000 per depositor for deposits held in the same “right and capacity.”...more

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

FDIC Proposes Guidelines Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total...

On October 3, 2023, the Federal Deposit Insurance Corporation (FDIC) approved proposed guidelines establishing standards for corporate governance and risk management for covered institutions with total assets of $10 billion...more

FinCEN Publishes Notice and Proposed Rule Related to CTA Beneficial Ownership Information System

Why it matters: Information gathered and maintained by FinCEN under the CTA will be exempt from notification and record access requirements, and individuals will not be permitted to contest the contents of a report if, for...more

Federal Banking Agencies Propose Basel III Endgame Capital Rules

On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more

CFTC Announces Two New Task Forces

In this Weekly Roundup Issue. The Commodity Futures Trading Commission’s (CFTC) Division of Enforcement unveiled two new task forces aimed at tackling derivatives market issues; and the Office of the Comptroller of the...more

Bank Regulators Issue Guidance for Third-Party Risk Management

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more

FDIC Refines Supervisory Strategy Concerning Multiple Re-Presentment NSF Fees Guidance

Regulatory Developments - FDIC Refines Supervisory Strategy Concerning Multiple Re-Presentment NSF Fees Guidance - On June 16, the FDIC revised its Supervisory Guidance on Multiple Re-Presentment Non-Sufficient Funds...more

Federal Agencies Propose Interagency Guidance on Reconsiderations of Value for Residential Real Estate Valuations

Regulatory Developments Federal Agencies Propose Interagency Guidance on Reconsiderations of Value for Residential Real Estate Valuations. On June 8, the CFPB, FDIC, Federal Reserve, NCUA, and OCC requested public comment on...more

Agencies Issue Final Guidance on Third-Party Risk Management

Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more

FDIC Issues a Proposed Rule on Special Assessment Pursuant to Systemic Risk Determination

In this Weekly Roundup Issue. The Federal Deposit Insurance Corporation (FDIC) issued a proposed rule to impose a special assessment pursuant to systemic risk determination; The Board of Governors of the Federal Reserve...more

CFPB Affirms Banks Risk UDAAP for Unilaterally Re-Opening Consumer Accounts After Account Closure

The Consumer Financial Protection Bureau (CFPB) warned banks that unilaterally re-opening consumer accounts after account closure could constitute an unfair act or practice and the Securities and Exchange Commission’s (SEC)...more

Federal Reserve Announces Results From the Review of the Supervision and Regulation of SVB

Regulatory Developments - Federal Reserve Announces Results From the Review of the Supervision and Regulation of SVB - On April 28, the Federal Reserve released its report analyzing SVB’s failure (Report). The Report...more

FDIC Pass-Through Coverage

Since the failure of Silicon Valley Bank in March of this year, there has been a renewed focus on Federal Deposit Insurance Corporation (FDIC) deposit insurance coverage, including arrangements that provide so-called...more

First Republic Bank FAQ

This FAQ was last updated at 3 pm EST on May 1, 2023. This is an evolving situation, and we will update this FAQ as more information becomes available. What happened with First Republic Bank? On May 1, 2023, First...more

FAQ About Recent Bank Failures in the US (Updated April 28, 2023)

Are the deposits at my bank FDIC-insured? Deposits held at FDIC-insured depository institutions are insured up to $250,000 per depositor for deposits held in the same “right and capacity” (see below)....more

Overdraft Protection Programs: Risk Management Practices

Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more

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