News & Analysis as of

Recordkeeping Requirements Depository Institutions

Venable LLP

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

Venable LLP on

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

Morrison & Foerster LLP

10 Tips for Fintechs in Navigating Sponsor Bank Relationships through this Banking Crisis

The current banking crisis, which in significant part has been focused on regional banks catering to fintech companies, is likely to result in increasing regulatory focus on an industry already subject to regulatory scrutiny....more

Goodwin

OCC Finalizes “True Lender” Rule

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

A&O Shearman

US Federal Deposit Insurance Corporation Extends Comment Period on Deposit Account Recordkeeping Proposal

A&O Shearman on

The FDIC extended the comment period for proposed recordkeeping requirements for FDIC-insured institutions with at least 2 million deposit accounts. The purpose of the proposed recordkeeping requirements is to facilitate...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume XI, Issue 8

BROKER-DEALER - FINRA Requests Information Regarding Firm Culture and Values - The Financial Industry Regulatory Authority is requesting firms to submit information regarding their organizational culture and how...more

Orrick - Finance 20/20

FDIC Seeks Comment on Proposed Deposit Account Records Requirements for Large Banks

Orrick - Finance 20/20 on

On April 21, the FDIC released an advanced notice of proposed rulemaking seeking comment on potential new recordkeeping standards for a limited number of FDIC-insured institutions with a large number of deposit accounts....more

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