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
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
A group of 11 financial services associations is calling on the FDIC to withdraw its notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered...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
The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more
On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...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 proposal seeks to make executive compensation arrangements more sensitive to risk and would require complex risk management programs to ensure compliance....more
The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more
The final rule issued in December 2023 by the Federal Deposit Insurance Corporation (FDIC) amending its regulations at 12 CFR Part 328 (“Final Rule“), which address use of the official FDIC sign and banks’ advertising...more
On January 29, 2024, the OCC issued a proposed policy statement[1] describing the general principles it uses to evaluate applications for approval of transactions under the Bank Merger Act (“BMA”), principally bank mergers,...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
The Federal Deposit Insurance Corporation (“FDIC”) Board voted (3-2) to propose a special assessment to recoup the expected $15.8 billion cost to the Deposit Insurance Fund “(DIF”) in the wake of invocation of the special...more
Federal Reserve Issues Policy Statement on Section 9(13) of the Federal Reserve Act - On January 27, the Federal Reserve issued a policy statement interpreting section 9(13) of the Federal Reserve Act, which authorizes...more
Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
On July 29, the FDIC issued a Fact Sheet and Advisory (collectively, the Published Documents) regarding FDIC deposit insurance and crypto assets. The Published Documents emphasize that FDIC deposit insurance does not apply...more
Regulatory Developments - OCC Solicits Research on Implications of Financial Technology for Banking - On July 25, the OCC is seeking academic and policy-focused research on the impact that fintech and non-bank...more
On May 5, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed rulemaking to...more
On March 22, the Federal Reserve Board issued a Notice of Proposed Rulemaking (“NPR”) that will be joined by the Federal Deposit Insurance Corporation, National Credit Union Administration and the Office of the Comptroller of...more
Now that the pandemic’s “social distancing” is lessening, we hope you are all able to gather with friends and family this Thanksgiving. As we do the same, we wanted to count our blessings as we review the year. This year, we...more
Federal Banking Agencies Issue Guide for Community Banks on Conducting Due Diligence on Fintech Companies - On August 27, 2021, the federal banking agencies (Federal Reserve, FDIC, and OCC) published “Conducting Due...more
On January 12, 2021, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) published a Notice of Proposed...more
The Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) recently announced a “Notice of Proposed...more
On March 17, 2020, the Federal Deposit Insurance Corporation (FDIC) approved Square Financial Services, Inc.’s (Square Financial) and Nelnet Bank’s applications for deposit insurance, subject to several conditions. The FDIC...more
Federal Reserve Revises Framework for Determining Control of a Banking Organization The Federal Reserve has adopted a final rule to simplify and clarify its regulations for determining control of a banking organization for...more