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This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more
This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
On March 3, 2025, the Federal Deposit Insurance Corporation (FDIC) announced the withdrawal of three proposed rules intended to reshape oversight and regulatory obligations related to brokered deposits, corporate governance...more
Recently, the FDIC Office of Inspector General released a report entitled, “FDIC Readiness to Resolve Large Regional Banks,” which evaluated the FDIC’s preparedness to resolve large regional bank failures under the Federal...more
On November 5, the FDIC announced plans to launch the Minority Banking Opportunity Explorer, an online tool designed to help financial institutions, investors, and other stakeholders identify neighborhoods that could benefit...more
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed amendments to regulations under the Change in Bank Control Act of 1978 (the CBCA) that would subject certain acquisitions of holding companies of...more
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
Executive Summary - Last month, the Federal Deposit Insurance Corporation (FDIC) Board of Directors (FDIC Board) proposed an amendment to its regulations under the Change in Bank Control Act of 1978 (CBCA). Driven by the...more
On August 9, 2024, the US Federal Deposit Insurance Corporation (FDIC) issued an interpretation of the exclusion of automated teller machines (ATMs) and remote service units (RSUs) from the definition of a domestic branch....more
The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would make significant revisions to the FDIC’s regulations implementing the provisions of Section 29 of the Federal Deposit...more
On July 18, the OCC, FDIC, and the Fed (the federal banking agencies or FBAs) submitted a brief requesting that the U.S. Court of Appeals for the Fifth Circuit hold oral argument and reverse the U.S. District Court for the...more
On May 2, the Governor of Florida signed into law HB 939 (the “Act”) which, among other things, will expand the definition of “depository institution” and amend the requirements for information returns relating to...more
On December 7, the FDIC released its semiannual update on the Restoration Plan for the agency’s Deposit Insurance Fund (DIF). The Federal Deposit Insurance Act (the FDI Act) requires that the FDIC board adopt a Restoration...more
The Federal Deposit Insurance Corporation (the “FDIC”) has issued a final rule that imposes a special assessment on insured depository institutions (“IDIs”) to recover losses realized by the Deposit Insurance Fund (the “DIF”)...more
On March 10, 2023 the California Department of Financial Protection and Innovation ("CDFPI") closed Silicon Valley Bank ("SVB"), a California chartered, non-member bank. The CDFPI placed SVB into receivership and appointed...more
The Federal Deposit Insurance Corporation (FDIC) continued the focus shown over the last several months, and especially since the March 2023 failure of Silicon Valley Bank (SVB) and associated events, by the federal banking...more
Since the failure of Silicon Valley Bank in March of this year, there has been a renewed focus on Federal Deposit Insurance Corporation (FDIC) deposit insurance coverage, including arrangements that provide so-called...more
In the wake of the Silicon Valley Bank and Signature Bank defaults, it is important for bank customers to understand the common cash management options and accounts available in financial institutions as well as their...more
Legislative responses to recent banking industry failures could include reinstating various rules that formerly applied to banks with more than $100 billion in assets. There are a variety of measures which bank depositors...more
The Federal Deposit Insurance Corporation (“FDIC”) guarantees bank deposits of up to $250,000. Following the failure of two banks in recent weeks, regulators created some confusion among the industry and the public when they...more
Now is the Time to Guard Against Reckless Banking Legislation - “Only a structural change to the way Congress acts on financial regulation will prevent future losses.” Why this is important: An old adage is that...more
On March 27, the FDIC sent a letter to a neobank demanding that it stop making false or misleading representations about FDIC deposit insurance and take immediate corrective action to address these statements. ...more
With the recent failures of Silicon Valley Bank on March 10, 2023, and Signature Bank on March 12, 2023, clients are asking whether their bank deposits are protected by Federal Deposit Insurance Corporation (FDIC) insurance....more
Many lessons will be learned from the failure of Silicon Valley Bank last weekend. The full story is unlikely to emerge for some time, but commentators have quickly reached a consensus on the likely causes. The central...more