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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

Irregular Time - A Quasi-Proposed Rule on Incentive-Based Compensation

For the third time, federal agencies have issued a proposed rule to regulate incentive-based compensation paid by certain financial institutions and other entities (the 2024 Proposal). The 2024 Proposal has been released by...more

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

The FDIC's Tougher Policy on Mergers - Why It Matters for Banks and Fintechs

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

Chalk Talk: OCC Re-Thinks Business Combinations

The OCC recently released a proposed rule and policy statement on business combinations involving national banks and federal savings associations (banks), which includes mergers, acquisitions of assets, and assumptions of...more

OCC's Latest Guidance on Buy Now, Pay Later Products Signals Increasing Federal Oversight

Consumer use of "buy now, pay later" (BNPL) products and programs has proliferated over the last few years. While federal oversight has not been extensive to date, new guidance from the Office of the Comptroller of the...more

Harder, Better, Faster, Stronger: The New Interagency Rule for the Community Reinvestment Act

After more than five years—with competing developments at times—the federal banking agencies (Federal Reserve, OCC, and FDIC) have revamped the regulations that implement the Community Reinvestment Act (CRA). The final...more

Financial Regulatory Reform Tracker - Anti-Tailoring Efforts

Following the 2023 bank failures, the federal banking regulators (the Federal Reserve, the OCC, and the FDIC) have signaled that they are seeking to develop more stringent bank regulatory requirements for larger banking...more

Federal Reserve Updates Framework for Stablecoins, Digital Assets, and Other New Tech Activities

On August 8, 2023, the Federal Reserve released new guidance for supervised banking organizations on how they can engage in certain crypto-asset-related activities. With the release of the guidance, the Federal Reserve...more

The FDIC Continues Its Crackdown on False or Misleading Deposit Insurance Advertising

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

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