News & Analysis as of

Banking Sector Federal Deposit Insurance Corporation Loans

Mayer Brown

US FDIC Requests Comment on Industrial Loan Company Framework

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On July 15, 2025, the Federal Deposit Insurance Corporation (“FDIC”) requested comment on its framework for reviewing applications for deposit insurance from industrial loan companies and industrial banks (collectively,...more

Orrick, Herrington & Sutcliffe LLP

FDIC requests information on industrial banks and loan companies

On July 15, the FDIC Board approved the publication of a request for information on how the FDIC should review filings submitted by industrial banks and industrial loan companies....more

Orrick, Herrington & Sutcliffe LLP

FDIC releases January 2025 CRA evaluations

On April 4, the FDIC released an updated list of state nonmember banks evaluated for compliance with the CRA during January 2025. The CRA mandates that the FDIC assess how well banks meet the credit needs of their entire...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

U.S. Supreme Court Draws the Line: Misleading Statements Aren’t Always False

Last week a unanimous U.S. Supreme Court issued an opinion in Thompson v. United States, 2025 WL 876266 (2025), holding that a statement that is literally true but allegedly misleading, is not a “false statement” under 18...more

Orrick, Herrington & Sutcliffe LLP

U.S. Supreme Court rules misleading statements to FDIC not criminal

On March 21, the U.S. Supreme Court issued an opinion regarding the meaning of “false statement” in 18 U.S.C. § 1014 which defines terms for those who knowingly make a false statement or report. The case’s petitioner had...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Finalize Interagency Policy Statement on CRE Loan Workouts

On June 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more

Troutman Pepper Locke

Federal Agencies Issue Joint Policy Statement on Commercial Loan Workouts

Troutman Pepper Locke on

On June 29, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (collectively, the agencies)...more

Foley & Lardner LLP

Ripple Effect of Recent Bank Insolvencies on Real Estate

Foley & Lardner LLP on

The closure of Silicon Valley Bank (SVB) and Signature Bank, and the subsequent receivership by the Federal Deposit Insurance Corporation (FDIC), has far-reaching effects, including to commercial real estate transactions in...more

Brownstein Hyatt Farber Schreck

Bank Failures Spark Liquidity Injection from FHLBanks

On Monday, March 13, the Federal Home Loan Bank (FHLBank) system issued a single-day record of $88.7 billion in short-term, floating-rate notes with maturities ranging from three months to one year. The system originally...more

Foley Hoag LLP

FDIC Creates Silicon Valley Bridge Bank, N.A. and Issues Updated FAQS

Foley Hoag LLP on

The FDIC has also posted updated FAQs on its website confirming that direct deposits and autopay will continue to operate and that checks will continue to clear. Customers with lines of credit are instructed to contact...more

Goodwin

FAQ About Recent Bank Failures in the US

Goodwin on

What actions did the US government take on Sunday with respect to Silicon Valley Bank (SVB) and Signature Bank? On Sunday, March 12, the FDIC, the Federal Reserve, and the US Treasury Department announced that the US...more

Fenwick & West LLP

Silicon Valley Bank Closure: Updated Considerations Following the Creation of Silicon Valley Bridge Bank, N.A.

Fenwick & West LLP on

Considerations relating to Silicon Valley Bank (SVB)’s closure have continued to evolve as a result of the recent announcement by the Federal Deposit Insurance Corporation (FDIC) that it has transferred all deposits—both...more

Foley Hoag LLP

Department of the Treasury, Federal Reserve, and FDIC Issue Joint Statement

Foley Hoag LLP on

On Sunday, March 12, 2023, the Treasury Department, the Federal Reserve, and the FDIC issued a joint statement indicating that there has been an agreement to roll out emergency measures to protect depositors at SVB. The...more

Fenwick & West LLP

Silicon Valley Bank Closure: Important Updates for Corporate Banking Customers

Fenwick & West LLP on

Last Updated: Sunday, March 12, 2023, 5 p.m. PDT On Friday, March 10, 2023, Silicon Valley Bank (SVB) was closed by the California Department of Financial Protection & Innovation, The Federal Deposit Insurance Corporation...more

Wilson Sonsini Goodrich & Rosati

Addressing Legal Issues Related to the Silicon Valley Bank Closure

On March 10, 2023, Silicon Valley Bank (SVB) was closed by the California Department of Financial Protection & Innovation, with the Federal Deposit Insurance Corporation (FDIC) appointed as receiver....more

Seward & Kissel LLP

Silvergate

Seward & Kissel LLP on

The FDIC generally shuts down failing institutions on Friday after the close of business to minimize disruptions to depositors....more

Ballard Spahr LLP

Bi-partisan group of Senators urge FDIC not to target industrial loan companies for unfavorable treatment

Ballard Spahr LLP on

A bi-partisan group of nine Senators (five Republicans and four Democrats) recently sent a letter to Acting FDIC Chairman Martin Gruenberg to express their support for the industrial loan company (ILC) charter and to remind...more

Husch Blackwell LLP

One Step Closer to Certainty: Court Dismisses States' Challenges to "Valid When Made" Rules

Husch Blackwell LLP on

On February 8, 2022, a federal district court in California issued separate orders concluding that the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) did not violate the...more

Buchalter

OCC and FDIC “Valid When Made” Rule Reaffirmed: Interest Rate Limitations, or Lack Thereof, on Loans Made By National and State...

Buchalter on

Under the long-recognized valid when made doctrine, if a loan was not subject to a state usury law when it was made, it does not subsequently become even if it is subsequently sold or assigned to another party. The doctrine...more

Goodwin

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

Goodwin on

In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Morrison & Foerster LLP

After Madden, OCC and FDIC Propose to Reaffirm “Valid When Made” Rule

Morrison & Foerster LLP on

On November 18, 2019, the Office of the Comptroller of the Currency (OCC) took action to reaffirm the “valid when made” doctrine in response to the uncertainty on the validity of interest rates of bank-originated loans sold...more

Balch & Bingham LLP

Eleventh Circuit Affirms Bank Directors’ Negligence in Approving Risky Loans

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The Eleventh Circuit recently considered a negligence claim brought by the FDIC against directors of a Georgia community bank. Before the 2008 financial crisis, Buckhead Community Bank undertook a growth strategy to expand...more

Orrick - Finance 20/20

FDIC Annual Publication Examines Potential Credit and Market Risks

The Federal Deposit Insurance Corporation (FDIC) published its annual review of the primary risk factors facing the banking system, focusing on the categories of credit risk and market risk. ...more

BCLP

Regulators Tackle Board Effectiveness and Overdrafts

BCLP on

Host Jonathan Hightower is joined by Ken Achenbach to discuss this week's proposed guidance from the Federal Reserve on the effectiveness of bank boards. In addition, at the outset of the episode Jonathan and Ken reviewed...more

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