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Proposed Rules Recordkeeping Requirements

Stikeman Elliott LLP

CIRO Publishes Phase 5 of its Rule Consolidation Project

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The Canadian Investment Regulatory Organization (“CIRO”) has published for comment Phase 5 of its rule consolidation project (the “Rule Consolidation Project”). Phase 5 involves rules relating to outsourcing and service...more

Seward & Kissel LLP

SEC Easing Conditions for Co-Investment Relief for BDCs and Closed-End Funds

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On April 3, 2025, the U.S. Securities and Exchange Commission (“SEC”) issued a notice of proposed exemptive relief to FS Credit Opportunities Corp. and its affiliates (Applicants), introducing more flexible co-investment...more

Bergeson & Campbell, P.C.

EPA Reopens Comment Period on Proposed Risk Management Rule for PV29

On March 4, 2025, the U.S. Environmental Protection Agency (EPA) announced that it is reopening the comment period for the January 2025 proposed rule to address the unreasonable risk of injury to human health presented by...more

Bradley Arant Boult Cummings LLP

OSHA Terminates COVID-19 Emergency Temporary Standard for Healthcare Workers

Is COVID-19 still a thing, and does OSHA care about it? Yes and yes. We all know that COVID-19 is still around. On the OSHA front, the agency seems to be focused less exclusively on COVID-19 and plans to take a broader...more

Orrick, Herrington & Sutcliffe LLP

FDIC receives letter from senators to finalize its custodial accounts rule

On January 16, the FDIC received a letter from Sens. Ron Wyden (D-OR) and John Fetterman (D-PA) urging the finalization of a proposed rule to strengthen recordkeeping for custodial accounts. As previously covered by...more

Conn Maciel Carey LLP

Biden’s OSHA Pushes Heat Illness Prevention Rule Close to the Finish Line

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On January 14, 2025, just six days before the transition from the Biden Administration to the second Trump Administration, OSHA closed the books on collecting public comments on the agency’s Notice of Proposed Rulemaking...more

Beveridge & Diamond PC

FDA Proposes New Rule on Testing Talc-Containing Cosmetic Products

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Mandatory testing of talc-containing cosmetic products is coming. At the end of December, the Food and Drug Administration (FDA) proposed a cosmetics rule and test method for asbestos in talc that was required under Section...more

ArentFox Schiff

FDA Issues New Cosmetics Proposed Rule: Let’s Talk About Talc

ArentFox Schiff on

Two years after the enactment of the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), the US Food and Drug Administration (FDA) has published the long-awaited proposed rule on talc-containing cosmetics....more

Troutman Pepper Locke

FDIC Extends Comment Period for Proposed Rule on Recordkeeping for Third-Party Deposits

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In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

DLA Piper

Bank Regulatory News and Trends

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This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape. In this edition: CFPB issues final rule on personal financial data rights...more

King & Spalding

What Does a Second Trump Administration Mean for the Private Funds Industry?

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The incoming Trump administration will bring significant changes to regulatory policy as it relates to the asset management industry, and private funds, in particular...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Proposes Rules Prohibiting and Restricting Certain Data Transactions to Address National Security Concerns

The Department of Justice’s (DOJ) proposed rule implements President Biden’s Executive Order (EO) on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of...more

Ropes & Gray LLP

DOJ Issues Notice of Proposed Rulemaking to Restrict Flow of Bulk Sensitive Personal Data to China and other Countries of Concern

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On October 29, 2024, the Department of Justice (“DOJ”) published its Notice of Proposed Rulemaking (“NPRM”) to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data...more

King & Spalding

Biden Administration Issues Proposed Rule Targeting “Connected Vehicles” Tied to China or Russia

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The Proposed Rule imposes substantial new reporting, diligence, and compliance obligations for companies in the automotive supply chain - On September 26, 2024, the U.S. Department of Commerce’s Bureau of Industry and...more

Jones Day

FDIC Proposes New Requirements for Custodial Accounts to Qualify for Pass-Through

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The Situation: On September 17, 2024, the Federal Deposit Insurance Corporation ("FDIC") approved a proposed rule ("the Proposal") that would establish new recordkeeping requirements for FDIC-insured depository institutions...more

Mayer Brown

FDIC’s New Recordkeeping Proposal

Mayer Brown on

Last month, the FDIC proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech partnerships, including some partnerships for programs that do not promise FDIC...more

Davis Wright Tremaine LLP

FDIC Proposes Rulemaking on Custodial Deposit Accounts in Wake of Synapse Bankruptcy

As part of a larger effort to address risks related to third-party deposit relationships, on October 2, 2024, the Federal Deposit Insurance Corporation (FDIC) announced and published a notice of proposed rulemaking (Proposed...more

Foley & Lardner LLP

Proposed Rule Targeting Connected Vehicles Will Impose Major New Supply Chain Compliance Requirements on Automotive Companies that...

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Share on Twitter Print Share by Email Share Back to top On September 26, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Notice of Proposed Rulemaking that, if finalized, would prohibit...more

Troutman Pepper Locke

FDIC Publishes Proposed Rule on Recordkeeping for Third-Party Deposits, Opens Comment Period

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We previously posted on the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies....more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2024

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

Cadwalader, Wickersham & Taft LLP

The FDIC’s Proposed “Synapse” Rule Affects Deposit Accounts Opened by Fintech Custodians

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

Ballard Spahr LLP

FDIC Issues Notice of Proposed Regulations for Enhanced Recordkeeping for Third-Party Custodial Accounts

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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

Orrick, Herrington & Sutcliffe LLP

FDIC issues NPRM requiring banks to provide accurate record-keeping in connection with third-party arrangements

On September 17, the FDIC released an NPRM aimed at strengthening record-keeping requirements for banks’ holding deposits from third-party non-bank companies (i.e., fintechs). The proposed rule seeks to mitigate risks among...more

Morrison & Foerster LLP

FDIC Issues Proposal to Improve Bank Recordkeeping of Fintech Custodial Accounts

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

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

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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

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