Saying that its proposed brokered deposits rule would have “significantly disrupted many aspects of the deposit landscape,” the FDIC has withdrawn the proposal. ...more
On March 3, 2025, the Federal Deposit Insurance Corporation (FDIC) announced the withdrawal of three proposed rules intended to reshape oversight and regulatory obligations related to brokered deposits, corporate governance...more
On March 3, 2025, the Federal Deposit Insurance Corporation (“FDIC”) withdrew its pending proposed rule on brokered deposits (the “Proposal”), originally published in the Federal Register on August 23, 2024. The Proposal,...more
James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the March 5, 2025 Banking Dive article, “FDIC Withdraws Merger Policy, Brokered Deposits Proposal.”...more
The FDIC has signaled the reversal of key, controversial proposals from 2024. In doing so, it has provided welcome clarity on important areas that implicate banks of various sizes and charter types, allowing banks to focus on...more
On January 20, the FDIC appointed Travis Hill as Acting Chairman. In a prepared statement the next day, Hill outlined his agenda to address changes at the Corporation. Among other efforts, he announced a wholesale review of...more
While the coming weeks and months will provide more clarity, we already can anticipate some indications of what is in store for bank regulation, supervision, and enforcement in a second Trump Administration. To help navigate...more
This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape. In this edition: CFPB issues final rule on personal financial data rights...more
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would unwind and considerably revise parts of the FDIC’s 2020 final rule governing brokered deposits (the “Proposed Rule”). The...more
Yesterday, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all...more
The Federal Deposit Insurance Corporation (FDIC) announced a proposed rule that would revise brokered deposit regulations promulgated under Section 29 of the Federal Deposit Insurance Act....more
In a recent news release, Acting Comptroller of the Currency Michael J. Hsu reiterated the Office of the Comptroller of the Currency's (OCC) support for the FDIC's Notice of Proposed Rulemaking on the brokered deposit rule....more
The proposal would make key changes to the definition of “deposit broker” with significant ramifications for banks, fintechs, bank-fintech partnerships, and other third parties in the financial services industry....more
In late July 2024, the Federal Deposit Insurance Corporation (FDIC) board of directors proposed a rule that would revise its standards on banks accepting brokered deposits. The proposed rule would expand the definition of...more
This monthly bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more
“In the worst case, these [newly designated brokered deposits] will have to get offloaded in a way that potentially puts those banks at even greater liquidity risk, especially to the extent that they have a higher...more
A group of 11 financial services associations is calling on the FDIC to withdraw its notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered...more
Currently, deposit accounts enabling payment transactions are automatically non-brokered, but the new rule will eliminate this designation, meaning parties relying on the “enabling transactions” exception will have to go...more
In a proposed rule and information request, the Federal Deposit Insurance Corporation expressed its concerns with the current brokered deposit restrictions and reporting requirements. Our Financial Services Team zeroes in on...more
One of the most fundamental activities of an insured depository institution (IDI) is taking and safekeeping customer deposits. However, a recent proposed rulemaking by the Federal Deposit Insurance Corporation (FDIC) poses...more
The FDIC recently proposed a rule that would substantially change the 2020 final rule on brokered deposits that largely liberalized the FDIC’s framework. The proposed rule would eliminate many of the changes from 2020 and...more
“Hot money” – as it was later dubbed – was viewed by skeptics as one of the major causes of the savings and loan crisis of the 1980s....more
On July 30, the FDIC released an NPRM that would provide restrictions, update definitions, and provide new exceptions to the rule on brokered deposits. The FDIC explained that these proposed amendments would simplify...more
1. Introduction and Summary - On July 30, 2024 – a mere 32 months after adopting a new regulatory framework for brokered deposits in December 2020 (the “Current Rules”) – the Federal Deposit Insurance Corporation (“FDIC”)...more
On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...more