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The GENIUS Act: What Is It and What’s Next?

On June 17, the U.S. Senate voted 68-30 to pass S.1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the Act). This represents a landmark effort by the U.S. Congress to...more

FDIC Withdraws Merger Policy, Brokered Deposits Proposal

James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the March 5, 2025 Banking Dive article, “FDIC Withdraws Merger Policy, Brokered Deposits Proposal.”...more

Legislation Introduced in the House Aims to Support New and Rural Banks by Easing Regulatory Requirements

On January 16, U.S. Representative Andy Barr (R-KY) introduced H.R. 478, the “Promoting New Bank Formation Act,” which was referred to the Committee on Financial Services. This bill aims to support the establishment and...more

FDIC Acting Chairman Hill Outlines Near-Term Policy Direction

On January 20, Travis Hill became the Acting Chairman of the Federal Deposit Insurance Corporation (FDIC). Following his remarks on FDIC policy issues on January 10 at the American Bankers Association, in his first statement...more

Braving the Bumps in Banking as a Service

“Banks have to have the policies, the personnel and the procedures in place to be able to appropriately satisfy the regulatory obligations with respect to [that] due diligence,”...more

FDIC Extends Comment Period for Proposed Changes to Brokered Deposit Regulations

Yesterday, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all...more

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

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

Georgia Grants Fiserv a Special Banking Charter: A Major Milestone for Fintech and Nonbank Direct Access to Card Networks

In a significant development since our last post, Fiserv’s application for a merchant acquirer limited purpose bank (MALPB) charter has been approved by the Georgia Department of Banking and Finance. This approval marks a...more

FDIC and OCC Finalize New Guidelines on Bank Mergers

Yesterday, both the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) finalized new guidelines regarding bank mergers. According to the agencies, these updates aim to enhance...more

FDIC Proposes New Rule to Strengthen Recordkeeping for Third-Party Deposits

On September 17, the Federal Deposit Insurance Corporation (FDIC) announced a notice of proposed rulemaking (Proposal) aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

Where Have All the New Banks Gone?

Regulators, Stevens said, calculate a de novo group’s capital requirement with a key principle in mind: an institution’s need to maintain about an 8% leverage ratio after three years of operations. That means that in addition...more

Turning Back the Clock: FDIC Proposes Significant Changes to 2020 Brokered Deposit Rule

On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s...more

FinCEN Proposes Rule to Strengthen AML/CFT Programs

On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

FinCEN Proposes Loosening Customer Identification Program Requirements

On March 29, the Federal Crimes Enforcement Network (FinCEN), in collaboration with other federal agencies, issued a Notice and Request for Information and Comment (Notice and Request) seeking public comment on its proposal...more

Applications for Georgia Merchant Acquirer Limited Purpose Bank Charter: A Positive Sign for Fintech and Nonbank Direct Access to...

On January 12, Fiserv announced that it filed an application with the state of Georgia for a merchant acquirer limited purpose bank (MALPB) charter. This application is a seismic development and positive sign for those in the...more

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