News & Analysis as of

Brokered Deposits Banking Sector

Cooley LLP

FDIC Withdraws Four Biden-Era Proposed Rules

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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

Seward & Kissel LLP

FDIC Withdraws Pending Proposed Rule on Brokered Deposits

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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

Troutman Pepper Locke

FDIC Withdraws Merger Policy, Brokered Deposits Proposal

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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

Orrick, Herrington & Sutcliffe LLP

FDIC Acting Chairman Hill outlines his agenda

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

DLA Piper

Bank Regulatory News and Trends

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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

Nelson Mullins Riley & Scarborough LLP

More Data Needed to Counter Narrative Linking Bank/FinTech Relationships with "Bank Runs"

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

Latham & Watkins LLP

FDIC Proposes to Revise Brokered Deposit Regulations

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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

Cooley LLP

FDIC’s Proposed Brokered Deposit Rule Could Adversely Impact Fintech-Bank Partnerships

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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

Orrick, Herrington & Sutcliffe LLP

FDIC issues NPRM on brokered deposits

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

Mayer Brown

The Pendulum Swings Back: FDIC Proposes Changes to Brokered Deposits Restrictions

Mayer Brown on

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s...more

Goodwin

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

Goodwin on

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

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2024

The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more

Nelson Mullins Riley & Scarborough LLP

[Webinar] Brokered Deposits Best Practices for Bank Fintech Partnerships - July 25th, 11:00 am - 12:00 pm ET

You're Invited! Nelson Mullins invites you to a one-hour webinar entitled, "Brokered Deposits Best Practices for Bank Fintech Partnerships," on July 25. Partners Brad Rustin and Craig Nazzaro along with associate Marianna...more

Ballard Spahr LLP

FDIC Announces New Resources For Brokered Deposits Regulation

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On April 1, 2021, the FDIC’s final rule issued in December 2020 revising its brokered deposits regulation became effective. The full compliance date for the final rule is January 1, 2022. The rule established a new...more

Troutman Pepper Locke

FDIC Launches Brokered Deposit Resource Webpage and ‎Provides Guidance for Expedited Processing of Notices for ‎Designated...

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Effective April 1, 2021, the Federal Deposit Insurance Corporation (“FDIC”) launched a “Brokered Deposit” bankers’ resource web page, concurrently with the effective date of its final rule ‎‎(the “Rule”)‎ to modernize the...more

Morrison & Foerster LLP

FDIC Brokered Deposits Final Rule: Key Aspects For Broker Dealers

On January 22, 2021, the Federal Deposit Insurance Corporation (“FDIC”) published its final rule (“Final Rule”) revising and modernizing its regulations related to brokered deposits and the interest rate restrictions that...more

Troutman Pepper Locke

FDIC Issues Final Rule to Modernize Brokered Deposit Regulation and Refines the Primary ‎Purpose Exception

Troutman Pepper Locke on

On December 15, 2020, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule ‎‎(the “Rule”)‎ ‎ to modernize its regulations that implement Section 29 of the Federal Deposit ‎Insurance Act (“FDI Act”). The FDIC...more

Ballard Spahr LLP

FDIC issues final rule on brokered deposits and interest rate limits applicable to less than well capitalized institutions

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The FDIC has issued a final rule that establishes a new framework for analyzing whether deposits made through deposit arrangements qualify as “brokered deposits” and amends the methodology for calculating the interest rate...more

Alston & Bird

FDIC Approves Final Rule on Brokered Deposits

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Our Financial Services & Products Group unpacks the Federal Deposit Insurance Corporation’s most significant changes to brokered deposit regulations since 1989....more

Troutman Pepper Locke

FDIC’s Final Rule on Brokered Deposits Adds Clarity to Fintech Partnerships and Other Common Arrangements

Troutman Pepper Locke on

On December 15, the Federal Deposit Insurance Corporation (FDIC) issued a final rule (Final Rule) establishing a new framework for analyzing whether bank deposits obtained through third-party arrangements are brokered...more

Goodwin

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

Goodwin on

In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

Morrison & Foerster LLP

FDIC Publishes Brokered Deposits Proposed Rule

On February 10, 2020, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule intended to modernize the regulatory treatment of brokered deposits (Proposed Rule). The Proposed Rule would amend 12 C.F.R....more

K&L Gates LLP

The FDIC Considers Modernizing its Brokered Deposit Rules

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Brokered deposits is a hot topic once again. On December 19, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) published an advance notice of proposed rulemaking and request for comment on possible updates to its...more

Polsinelli

House Subcommittee Supports Revised Treatment of Reciprocal Deposits

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On Tuesday, a bipartisan group of legislators expressed their support for a bill (H.R. 4116) that would attempt to codify and expand a measure regarding reciprocal deposits that was included in FDIC’s final rule on small bank...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume X, Issue 6

In this issue: - SEC Publishes Rules for Reporting Security-Based Swaps - SEC Proposes Rules for Disclosure of Companies’ Hedging Policies - CFTC Extends Relief From Certain OCR Requirements - NFA...more

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