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DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

FDIC Withdraws Pending Proposed Rule on Brokered Deposits

On March 3, 2025, the Federal Deposit Insurance Corporation (“FDIC”) withdrew its pending proposed rule on brokered deposits (the “Proposal”), originally published in the Federal Register on August 23, 2024. The Proposal,...more

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

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

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