Consumer Finance Monitor Podcast Episode: How a Former FDIC Chairman is Reacting to the Silicon Bank Valley Failure, A Discussion with Special Guest Bill Isaac, Chairman, Secura/Isaac Group, and FDIC
Making Cents of Your Cash Management Agreements
In early March, nearly a year and a half after it was initially proposed, the Massachusetts Attorney General's Office finalized the Commonwealth's "junk fee" regulation (the "Final Rule") while simultaneously issuing a...more
The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more
On September 17th, the Federal Deposit Insurance Corporation ("FDIC") issued a proposed rule entitled “Recordkeeping for Custodial Accounts” with comments due sixty days from the date of publication in the Federal Register...more
On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more
As a lending lawyer for more than a quarter century at this point, I have seen that deposit accounts and deposit account control agreements are a routine component of virtually every transaction. Deposit accounts are a source...more
On September 17, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would significantly impact the risk management and oversight requirements for bank-fintech arrangements. This proposal comes in...more
The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more
On September 11, 2024, the CFPB issued an administrative consent order against the Bank, alleging multiple violations of the Fair Credit Reporting Act (FCRA), the Consumer Financial Protection Act (CFPA), and the Furnisher...more
After an intense 2023 rulemaking, supervisory, and enforcement cycle for the federal banking agencies, the FDIC issued a final rule on FDIC official signs and advertising requirements right before the new year. The rule comes...more
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
The Federal Deposit Insurance Corporation (FDIC) continued the focus shown over the last several months, and especially since the March 2023 failure of Silicon Valley Bank (SVB) and associated events, by the federal banking...more
On June 15, the FDIC sent letters ordering three companies and certain of their officers to cease and desist from using the agency’s logo and making false and misleading statements about FDIC deposit insurance. The companies...more
The United States District Court for the Eastern District of Virginia recently affirmed a basic principle of deposit banking, which is that in the absence of an express agreement, a depository bank owes no duty to...more
In response to the recent bank failures, on May 1, 2023, the Federal Deposit Insurance Corporation (FDIC) released a report titled “Options for Deposit Insurance Reform” (Report). The Report provides a comprehensive overview...more
Today, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking that would impose special assessments to recover losses to the Deposit Insurance Fund (DIF) arising from the FDIC’s protection...more
A toxic combination of poor risk management and poor regulatory supervision proved fatal for Silicon Valley Bank (“SVB”) and Signature Bank (“Signature”), according to a series of reports released on April 28, 2023 by federal...more
On May 1, the Federal Deposit Insurance Corporation (FDIC) released a report titled Options for Deposit Insurance Reforms, which outlines three options to reform the nation's deposit insurance system. The three options...more
On March 8, the CFPB released a special edition of its Supervisory Highlights reporting on unlawful junk fees that were uncovered in a variety of servicing markets, including bank account deposits, auto loan servicing,...more
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
Federal Deposit Insurance Corporation (“FDIC”) Vice Chair Travis Hill gave a speech earlier this week, titled “Recent Bank Failures and the Path Ahead,” at the Bipartisan Policy Center. The speech appears to be Vice Chair...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