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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

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

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

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

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

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

Silicon Valley Bank FAQ

I had deposits at Silicon Valley Bank (SVB) that were assumed by First Citizens Bank. Are my deposits fully insured? Deposits at First Citizens are insured up to the standard maximum deposit insurance amount, which is...more

FDIC Publishes Consumer Compliance Supervisory Highlights

Regulatory Developments - FDIC Publishes Consumer Compliance Supervisory Highlights - On April 5, the FDIC published its latest edition of Consumer Compliance Supervisory Highlights (the Highlights). This edition of...more

FAQ About Recent Bank Failures in the US (Updated April 12)

I had deposits at Silicon Valley Bank (SVB) that were assumed by First Citizens. Are my deposits fully insured? Deposits at First Citizens are insured up to the standard maximum deposit insurance amount, which is $250,000...more

The U.S. Government Takes Action on the Silicon Valley Bank and Signature Bank Failures

Regulatory Developments - The U.S. Government Takes Action on the Silicon Valley Bank and Signature Bank Failures - On March 12, the FDIC, the Federal Reserve, and the U.S. Treasury Department announced that the U.S....more

Turbulent Banking Sector Renews Interest in Cash Management and Investment Policies

Silicon Valley Bank was a leading bank for the tech and life science sectors and for many of the venture capitalists who invest in those sectors. The bank’s abrupt disclosure on Wednesday, March 8, of significant losses on...more

FAQ About Recent Bank Failures in the US

What actions did the US government take on Sunday with respect to Silicon Valley Bank (SVB) and Signature Bank? On Sunday, March 12, the FDIC, the Federal Reserve, and the US Treasury Department announced that the US...more

FAQ About the Silicon Valley Bank Situation in the US

What happened to Silicon Valley Bank (SVB) on March 10? ..The California Department of Financial Protection and Innovation took possession of SVB on Friday morning, March 10, 2023, and appointed the Federal Deposit...more

Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities

Regulatory Developments - Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities - On February 23, the Federal Reserve, FDIC and OCC (the Agencies) issued a “Joint...more

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