This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more
This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
5/7/2025
/ Acquisitions ,
Bank Holding Company ,
Bank Holding Company Act ,
Banking Sector ,
Banks ,
Capital Requirements ,
Community Reinvestment Act ,
Controlling Stockholders ,
Depository Institutions ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Investors ,
National Bank Charters ,
Shareholders ,
Supervision
This is the first in a series of articles in our "So, You Want to Be a Bank?" series.
More than 1,000 new banks were formed in the eight years before the Great Recession began in 2008. In comparison, the past 15 years...more
5/1/2025
/ Acquisitions ,
Banks ,
Business Formation ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
Lenders ,
Mortgages ,
National Bank Charters ,
Regulatory Reform
Hi, thanks so much for joining us. I’m Samantha Kirby, chair of financial services here at Goodwin, and today, we’re going to talk to you about what we’re watching with respect to the bank regulatory agencies and the Consumer...more
4/23/2025
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
OCC ,
Proposed Rules ,
Regulatory Reform ,
Trump Administration
On January 1, 2025, Massachusetts Gov. Maura Healey approved House Bill No. 4840, which repeals and replaces Massachusetts’ money transmission law with a revised law (MTL Law), which is based in part on the model Money...more
1/17/2025
/ Amended Legislation ,
Banking Sector ,
Compliance ,
CSBS ,
Financial Services Industry ,
Licensing Rules ,
Money Transmission Act ,
Payment Systems ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more
9/19/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Compliance ,
Compliance Dates ,
Data-Sharing ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Investment Funds ,
Patriot Act ,
Suspicious Activity Reports (SARs)
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
9/19/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Compliance ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Internal Controls ,
Patriot Act ,
Policies and Procedures ,
Popular ,
Proposed Amendments ,
Proposed Rules ,
Risk Assessment
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Residential Real Estate Rule) requiring certain persons involved in residential real estate closings and...more
9/19/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cash Transactions ,
Compliance ,
FinCEN ,
Geographic Targeting Order ,
Real Estate Transactions ,
Real Estate Transfers ,
Reporting Requirements ,
Residential Property Owners ,
U.S. Treasury
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
8/9/2024
/ Banking Sector ,
Compliance ,
Consent Order ,
Enforcement Actions ,
Enforcement Priorities ,
Financial Regulatory Agencies ,
FinTech ,
Global Systemically Important Banks (G-SIBs) ,
Internal Controls ,
Policies and Procedures ,
Risk Management ,
Supervision
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
8/5/2024
/ Bank Deposits ,
Banking Sector ,
Broker-Dealer ,
Brokered Deposits ,
Brokers ,
Comment Period ,
Depository Institutions ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Proposed Rules
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
7/1/2024
/ Bank Holding Company Act ,
Business Model ,
Community Banks ,
Compliance ,
Deposit Insurance ,
Dodd-Frank ,
EGRRCPA ,
FDIC ,
FinTech ,
Fintech Charter ,
Non-Bank Lenders ,
Nonbank Firms ,
Volcker Rule
On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more
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
The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more
2/19/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
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
1/10/2024
/ Banking Crisis ,
Banks ,
Contract Terms ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Financial Institutions ,
Investment Management ,
Loans ,
Money Market Funds ,
Mutual Funds ,
Portfolio Managers ,
Receivership ,
Silicon Valley ,
State Charters ,
Systemic Risk Buffer ,
Transfer Agents
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
1/4/2024
/ Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Effective Date ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Joint Policy Statements ,
National Security ,
Penalties ,
Reporting Requirements ,
U.S. Treasury
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
On October 24, 2023, the Board of Governors of the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the Agencies) approved long-awaited final...more
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
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
8/4/2023
/ Banking Crisis ,
Banking Regulators ,
Banking Sector ,
Basel III ,
Capital Requirements ,
Comment Period ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Large Financial Institutions (LFIs) ,
OCC ,
Proposed Regulation ,
Silicon Valley ,
Systemic Risk Buffer
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
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
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
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
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
4/13/2023
/ Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Foreign Branch Offices ,
Offshore Banks ,
Receivership ,
Relief Measures ,
Silicon Valley ,
U.S. Treasury