News & Analysis as of

Comment Period Banking Sector

Davis Wright Tremaine LLP

FDIC Proposes Adding Flexibility to Official Sign and Advertising Requirements

On August 21, 2025, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule with several key changes to its FDIC Official Sign and Advertising Rule, only two years after it adopted requirements that were...more

Saul Ewing LLP

Open Call: CFPB Seeks Comments on New Section 1033 Open Banking Rule

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The first step in the future of open banking under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank" or the "Act") is here: in a notice posted August 22, 2025 (the "Notice"), the Consumer Financial...more

Orrick, Herrington & Sutcliffe LLP

FDIC proposes rule to update its digital signage requirements

On August 19, the FDIC announced that its board approved a proposed rule to amend signage requirements for banks’ digital deposit channels and ATMs. The proposal aims to reduce implementation issues, reduce burden, and...more

A&O Shearman

UK CMA Proposes Releasing Remaining Provisions in the SME Banking Undertakings 2002

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The Competition and Markets Authority (CMA) published its provisional decision that the remaining provisions of the SME Banking (Behavioural) Undertakings 2002 (the 'Limitation on Bundling Provisions') are no longer...more

Alston & Bird

FDIC Takes First Steps in Revising Supervisory Appeals Processes

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Our Financial Services Team examines a proposed rule by the Federal Deposit Insurance Corporation (FDIC) that would revise its process for institutions to appeal material supervisory determinations....more

Orrick, Herrington & Sutcliffe LLP

U.S. Senate banking committee requests extension for comment period on proposed leverage ratio rule

On August 8, several members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs sent a letter to the heads of the Fed, the FDIC, and the OCC. The letter requested more rigorous data and analysis on the...more

A&O Shearman

UK PRA consults on restatement of CRR definitions in Rulebook

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The UK Prudential Regulation Authority (PRA) has published consultation paper CP19/25, proposing the transfer of definitions from Articles 4, 4A, 4B and 5 of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook...more

Davis Wright Tremaine LLP

FDIC Proposes to Bring Back Office of Supervisory Appeals

On July 18, 2025, the Federal Deposit Insurance Corporation (FDIC) released a proposal to amend its Guidelines for Appeals of Material Supervisory Determinations (Guidelines) to reinstate the Office of Supervisory Appeals...more

A&O Shearman

Mansion House: HMT publications on new regulated activity of providing targeted support

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HM Treasury (HMT) has published a draft statutory instrument (SI) and policy note on providing targeted support. The draft SI amends the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 by specifying...more

A&O Shearman

Mansion House: Bank of England measures to maintain a fit for purpose resolution regime

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The Bank of England (BoE) has published a suite of publications in its capacity as the UK′s resolution authority, covering significant updates in relation to its approach to setting the minimum requirement for own funds and...more

A&O Shearman

EBA consults on draft RTS and guidelines for third country branches under CRD IV

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The European Banking Authority (EBA) has published three consultation papers under Directive 2013/36 (CRD IV), as amended by Directive 2024/169 (CRD VI), relating to the regulatory requirements for third country branches...more

A&O Shearman

EBA consults on amending RTS on own funds and eligible liabilities under CRR

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The European Banking Authority (EBA) has published a consultation paper proposing amendments to Commission Delegated Regulation (EU) No 241/2014 on the timing for the application for prior permission to reduce own funds and...more

A&O Shearman

EBA consults on revision to POG guidelines for ESG retail banking products

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The European Banking Authority (EBA) has published a consultation paper on proposed revisions to its product oversight and governance (POG) guidelines for retail banking products. The EBA considers the update necessary in...more

Mayer Brown Free Writings + Perspectives

US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform

Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more

A&O Shearman

Basel Committee on Banking Supervision consults on amendments to principles for the management of credit risk

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The Basel Committee on Banking Supervision (Basel Committee) published a consultative document on updating the principles for the management of credit risk. The principles, first issued in October 2000, provide guidelines for...more

Orrick, Herrington & Sutcliffe LLP

CFPB issues new proposal to ban certain financial contract terms

On January 13, the CFPB proposed a new rule to ban large banks and consumer finance companies from using certain contractual provisions in agreements with consumers under Regulation AA. The CFPB’s proposal warns against the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2024

The CFPB has adopted a final rule to extend its oversight to the largest nonbank providers of digital consumer payment applications, including those that enable transfers from deposit accounts held at banks and other insured...more

Orrick, Herrington & Sutcliffe LLP

FDIC extends comment period for its custodial account NPRM

On November 18, the FDIC announced it would extend the comment period for its NPRM on recordkeeping for custodial deposit accounts by 45 days. The initial comment period, which began on October 2 was set to close on December...more

Orrick, Herrington & Sutcliffe LLP

GOP members of Financial Services Committee pen letter on bank-fintech partnerships

On October 30, Republican congressmembers serving on the U.S. House Committee on Financial Services responded to a joint Request for Information (RFI) issued by the OCC, the Fed and the FDIC. The RFI solicited input on...more

Orrick, Herrington & Sutcliffe LLP

FDIC extends comment period for proposed rule for another month

On October 16, the FDIC extended the comment period for a proposed rule change under the Change in Bank Control Act (CBCA) to November 18. As previously covered by InfoBytes, the proposed rule would amend the regulations...more

Mayer Brown

FDIC’s New Recordkeeping Proposal

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Last month, the FDIC proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech partnerships, including some partnerships for programs that do not promise FDIC...more

Orrick, Herrington & Sutcliffe LLP

FDIC extends comment periods on brokered deposit NPR, deposit data RFI

On October 8, the FDIC announced an extension of the comment period on its NPR to provide restrictions, update definitions, and provide new exceptions to the FDIC’s safety and soundness rule on brokered deposits (12 CFR...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other...

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On July 25, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a “Joint Statement on Banks’...more

A&O Shearman

UK Payment Systems Authority Consults on Draft Statement of Policy on its Cost Benefit Analysis Framework

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The Payment Systems Authority has published a consultation paper on a draft statement of policy on its cost benefit analysis (CBA) framework. The draft statement builds on and replaces the draft CBA framework published...more

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

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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

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