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

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

FDIC Finalizes Large Bank Resolution Plan Rule and OCC Proposes Changes to Recovery Plans

The FDIC recently finalized its resolution planning rule for large banks, which becomes effective October 1, 2024. Resolution plans, or "living wills," are plans to wind down operations in the event of bank failures. The...more

Fintechs, Novel Charters, and Fed Master Accounts - Of Elephants and Mouseholes

A U.S. District Court recently rejected arguments that banks and institutions with novel charters have a statutory right to obtain a Federal Reserve master account. Master accounts let institutions access key parts of the...more

New Year, New Signs - FDIC Amends Deposit Insurance Sign and Advertising Regulations

After an intense 2023 rulemaking, supervisory, and enforcement cycle for the federal banking agencies, the FDIC issued a final rule on FDIC official signs and advertising requirements right before the new year. The rule comes...more

Uninsured Deposits and the FDIC Final Rule for Special Assessments on Banks

The FDIC recently approved a final rule to impose a special assessment on banks to recover losses in connection with the decision to guarantee uninsured deposits at two failed banks in March 2023. No banking organizations...more

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