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Important Reminder About State-Chartered Credit Union Restrictions

During the past 12-18 months, we have noted a significant increase in the number of brokers underwriting share certificates issued by credit unions. It is vital for brokers in the credit union share certificate market to...more

FDIC Whipsaws Industry with Proposed Changes to Brokered Deposits Rules

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

August 30 Deadline for TIC Form SHL

Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

SEC Amends Regulation S-P to Require Data Breach Notifications and Additional Written Policies

On May 16, 2024, the SEC amended Regulation S-P to impose new data privacy and security requirements on broker-dealers, registered investment advisers, investment companies (whether or not they are registered with the SEC),...more

FDIC Extends Comment Period on Rule Imposing Additional Deposit Insurance Disclosure Obligations

The Federal Deposit Insurance Corporation (FDIC) announced today a 45-Day extension to the public comment period for proposed changes to its regulations that may significantly affect banks, broker-dealers, and FinTechs. The...more

Proposed FDIC Rule Would Impose Additional Deposit Insurance Disclosure Obligations on Banks and Non-Banks

The Federal Deposit Insurance Corporation (“FDIC”) published for comment in December 2022 a notice of proposed rulemaking (12 CFR Part 328) (“Proposed Rule”) that would apply to all FDIC-insured institutions and impose new...more

FDIC Recognizes Additional Designated Business Relationship Meeting Primary Purpose Exemption

The Federal Deposit Insurance Corporation (“FDIC”) has recognized a new designated business relationship that confirms that an agent, such as a broker-dealer, placing deposits of a customer with an insured depository...more

FDIC Staff Issues Statement Requiring Banks to Scrutinize Primary Purpose Exception Notices

On July 15, 2022, the Division of Risk Management Supervision (the “Staff”) of the Federal Deposit Insurance Corporation (“FDIC”) published a two-page statement (the “Statement”) “to remind” insured depository institutions...more

Proposed CA Crypto Regulatory Scheme Would Require Licenses, Disclosures for Digital Asset Businesses

A bill approved by the California State Assembly and pending in the state senate would require businesses in the cryptocurrency industry to obtain licenses from the state’s Department of Financial Innovation and Protection...more

FDIC Adopts Rule Prohibiting Misleading Statements About FDIC Insurance that Impacts a Broad Range of Deposit Placement...

Introduction - On May 17, 2022, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) adopted a final rule (“Rule”) setting forth its procedures for investigating and enforcing false advertising,...more

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