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 (Federal Deposit Insurance Corporation) is inviting public feedback on a proposed rule that aims to levy a special assessment on all banks with FDIC-insured deposits. Set to go into effect on January 1, 2024, the...more
The Federal Deposit Insurance Corporation (“FDIC”) published for comment in December 2022 a notice of proposed rulemaking (12 CFR Part 328) (“Proposed Rule”) that would apply to all FDIC-insured institutions and impose new...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more
In This Issue. The Small Business Administration (SBA) provided guidance on a borrower’s good faith certification on the necessity of Paycheck Protection Program (PPP) loan requests, announcing a safe harbor regarding this...more
The FDIC has issued a proposed rule setting forth the conditions it would impose and the commitments it would require to approve a deposit insurance application from an industrial bank or industrial loan company...more
On March 17, the FDIC released for public comment a proposed rule for industrial banks and industrial loan companies (together, “ILCs”) and their parent companies and signaled that it is considering two pending ILC...more