What Happened? On October 3, 2024, the CFPB released a Nonbank Registration: Orders Rule Coverage Chart (the “Chart”) that summarizes how an entity that is subject to an order may determine if it must register that order...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
Last week, each of the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Department of Justice Antitrust Division (DOJ) revised how they will review bank mergers. Our...more
Our Financial Services Team studies the Federal Deposit Insurance Corporation’s plans to require insured depository institutions (IDIs) to keep specific records so that they know the actual owner of deposits placed by...more
The Federal Deposit Insurance Corporation (“FDIC”) proposed in its Notice of Proposed Rulemaking (“NPR”) that insured IDIs keep records of individual accounts that are typically held in pooled custodial accounts that support...more
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule (the “Proposed Rule”) intended to strengthen recordkeeping for banks that partner with third-party, non-bank companies to accept...more
On July 30, 2024, the Federal Deposit Insurance Corporation (“FDIC”) Board of Directors approved a final rule that updates the FDIC’s regulations concerning Section 19 of the Federal Deposit Insurance Act, 12 U.S.C.§ 1829...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
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a notice of proposed rulemaking (NPR) that would expand the FDIC’s role under the Change in Bank Control Act of 1978 (CBCA). The NPR seeks, in part, to...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
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 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
The Situation: The Federal Deposit Insurance Corporation (FDIC) has issued a final rule which substantively changes the scope and expectations for Insured Depository Institution (IDI) resolution plans (FDIC Final Resolution...more
The Federal Deposit Insurance Corporation (FDIC) has recently issued a final rule amending its regulations governing the use of official FDIC signs and insured depository institutions’ (IDIs) advertising statements. The new...more
The Federal Deposit Insurance Corporation (the “FDIC”) has issued a final rule that imposes a special assessment on insured depository institutions (“IDIs”) to recover losses realized by the Deposit Insurance Fund (the “DIF”)...more
In Short - The Situation: The Federal Deposit Insurance Corporation ("FDIC") has proposed significant amendments (the "Proposal") to its rule requiring covered insured depository institutions ("CIDIs") to prepare and file...more
On August 29, at a Board Meeting for the Federal Deposit Insurance Corporation (FDIC), Comptroller of the Currency Michael J. Hsu issued a statement supporting the insured depository institution (IDI) Resolution Plan Rule,...more
To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more
On July 24, the FDIC released a letter reporting that some insured depository institutions (IDIs) are not accurately reporting their estimated uninsured deposits as per the instructions on the Call Report. According to the...more
On July 15, the Federal Deposit Insurance Corporation (“FDIC”) issued an updated Q&A regarding how companies involved in managing deposits can determine whether such deposits should be considered brokered, and/or whether they...more
On May 17, 2022, the Federal Deposit Insurance Corporation (“FDIC”) adopted a final rule establishing a new subsection B to the Federal Deposit Insurance Act (“FDIA”) addressing False Advertising, Misrepresentation of Insured...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more
On December 14, 2021, the U.S. Office of the Comptroller of Currency (“OCC”) adopted a new final rule (“Final Rule”) under the Community Reinvestment Act of 1977, as amended (the “CRA”) which will be effective on...more
On November 1, 2021, the President’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (together, the “Agencies”),...more
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