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
9/19/2024
/ Banking Sector ,
Banks ,
Comment Period ,
Compliance ,
Deposit Accounts ,
Depository Institutions ,
FBOs ,
FDIC ,
Financial Services Industry ,
FinTech ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements
Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more
On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more
7/31/2024
/ Banking Sector ,
Comment Period ,
Compliance ,
Federal Bank Regulatory Agencies ,
Financial Institutions ,
FinTech ,
Joint Statements ,
Public Comment ,
Request For Information ,
Risk Assessment ,
Risk Management
In the last of a series of watershed opinions this term that curtail federal agency power, the Supreme Court in Corner Post, Inc. v. Board of Governors of the Federal Reserve System has ruled (6-3) that the statute of...more
7/3/2024
/ Administrative Procedure Act ,
Chevron Deference ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Debit Cards ,
Dodd-Frank ,
Financial Institutions ,
FinTech ,
Interchange Fees ,
SCOTUS ,
Statute of Limitations ,
Treasury Regulations
The FDIC proposed revisions last month to its existing policy on how it evaluates merger transactions that require the FDIC's approval under the Bank Merger Act (BMA). ...more
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
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
1/24/2024
/ Advertising ,
Amended Regulation ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
Digital Communications ,
FDIC ,
Final Rules ,
FinTech ,
Internal Controls ,
Policies and Procedures ,
Signs ,
Third-Party Service Provider
Everyone—including fintechs, other non-bank companies, and associated individuals—that either partners with banks or seeks to provide alternatives to insured deposits must comply with the FDIC's deposit insurance advertising...more