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
On July 27, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, FBAs) issued their long-awaited...more
On April 28, 2023, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the United States Government Accountability Office (GAO), and the New York Department of...more
In contrast with the White House’s position, the Vice Chairman denied that loosened Dodd-Frank rules contributed to the recent bank failures. On April 12, 2023, Federal Deposit Insurance Corporation (FDIC) Vice Chairman...more
On March 10, 2023, the United States suffered the first major bank failure since the 2008 economic collapse. It was the nation’s 16th largest bank, with over $200 billion in assets....more
The Federal Reserve, OCC and FDIC have (finally) issued the Final HVCRE Rule (for background, our analysis of the 2018 Notice of Proposed Rulemaking and 2019 Notice of Proposed Rulemaking are here and here), regarding High...more
OCC and FDIC Propose Interest Rate Fix for Loans Transferred to Non-Banks - The FDIC and OCC have separately proposed rules that would codify the “valid-when-made” doctrine and clarify that when a bank sells, assigns, or...more
On September 17, 2019, the Federal Deposit Insurance Corporation (the “FDIC”) passed a final rule providing qualifying community banking organizations the ability to opt-in to a new community bank leverage ratio (“CBLR”)...more
Federal Banking Agencies Expand Eligibility to Use Streamlined Call Reports - The federal banking agencies have adopted a final rule to reduce regulatory reporting requirements for certain banks with total assets of less...more
FDIC Shares Examiners’ Expectations for Contracts with Technology Service Providers - The FDIC has issued guidance on examiners’ expectations for provisions of contracts between banks and technology service providers...more
FDIC Approves 3-Year Phase-In for Adverse Effects on Capital from CECL - The FDIC has approved a final rule that will provide banks with the option to phase in over a three-year period the day-one adverse effects on...more
Federal Banking Agencies Propose Alternative Capital Framework for Community Banks - The federal banking agencies have proposed a new community bank leverage ratio (“CBLR”) framework that would simplify regulatory capital...more
On October 2, 2018, the U.S. Senate’s Banking Committee held a hearing to review regulators’ implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) since its passage in June. As framed...more
The U.S. Federal Deposit Insurance Corporation published a notice of proposed rulemaking and request for comments regarding a limited exception for a capped amount of reciprocal deposits from treatment as brokered deposits. ...more