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What the Proposed Resolution Plan Rule Means for Smaller Banks

The FDIC’s proposed bank resolution planning rule would make significant changes to its current rule and would cover more banks—including banks that have been subject to a moratorium on filing for the past five years. Other...more

CFPB Weighs in on Credit Denials by Lenders When Using AI and Complex Credit Models

The CFPB has issued a Circular addressing adverse action notification requirements and the proper use of the CFPB's sample forms provided in Regulation B when using artificial intelligence (AI) and complex credit models, and...more

Breaking Down the Proposed Rule to Bail In More Banks

As part of the continuing financial regulatory reform efforts following the 2023 bank failures, the FDIC, the OCC, and the Federal Reserve issued a proposed rule that would generally require large banks and thrifts with total...more

All Things Seen and Unseen: Bank Supervision and Enforcement After the Spring 2023 Bank Failures

Besides being a shock to the market, the 2023 bank failures caused many to ask whether the federal banking agencies had done enough to prevent them. Precisely what the agencies should have done, or should do moving forward,...more

What the Proposed Capital Rule Means for Smaller Banks and Other Non-Bank Participants in the Financial Services Market

Larger banking organizations directly affected by the U.S. federal banking agencies' recent proposed capital rule have been busy analyzing the substantial changes, increased costs, and other requirements and effects that have...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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