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
The UK Bank of England (BoE) has published its consultation paper CP4/25 which contains proposals for depositor protection and the new resolution tool proposed by the Bank Resolution (Recapitalisation) Bill. The consultation...more
Proposed increases in the deposit protection limit from £85,000 to £110,000 and in the temporary high balance limit from £1 million to £1.4 million would take effect from 1 December 2025. There would be a transitional period...more
During the past 12-18 months, we have noted a significant increase in the number of brokers underwriting share certificates issued by credit unions. It is vital for brokers in the credit union share certificate market to...more
On November 18, CFPB Director Rohit Chopra released a statement in connection with an FDIC Board of Directors closed meeting to discuss deposit insurance reform following the failure of a small community bank in Oklahoma. The...more
In the absence of modern charters and licenses, payments companies and other fintechs—both established financial services providers and new market entrants—must generally obtain 50+ money transmitter and possibly other state...more
The CFPB has approved a final rule that requires banks and certain other financial services providers to share a consumer’s personal financial data with another provider at the consumer’s request. The CFPB’s Personal...more
The FDIC has issued a revised list of Q&As concerning the agency’s new rule governing the use of the agency’s official sign....more
On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more
The Federal Deposit Insurance Corporation (FDIC) has recently issued a final rule amending its regulations governing the use of official FDIC signs and insured depository institutions’ (IDIs) advertising statements. The new...more
The FDIC recently sent a warning letter to a fintech firm that made misleading references to the availability of deposit insurance in promotional materials used for various crypto-related products. Unbanked, Inc, which...more
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
In June, the Consumer Financial Protection Bureau’s (CFPB) Office of Competition and Innovation and Office of Markets issued an analysis of deposit insurance coverage on funds stored through popular payment companies, finding...more
The CFPB has issued an “Issue Spotlight” titled “Analysis of Deposit Insurance Coverage on Funds Stored Through Payment Apps.” The report was accompanied by a consumer advisory on payment apps....more
The Federal Reserve recently published a whopping 118-page review of the failure of Silicon Valley Bank (SVB), and three days later the FDIC published a 75-page report outlining several ideas to reform our deposit insurance...more
Banks are Borrowing Less from the Federal Reserve - “’So the fact that they are now borrowing less means that they’re trying to get back to normal.’” Why this is important: Investors and commentators look to several...more
FDIC and OCC Issue Guidance on Authorize Positive, Settle Negative Overdraft Fee Risks. The FDIC and the OCC each have issued supervisory guidance on consumer compliance risk exposure related to the assessment of overdraft...more
On April 11, 2023, the Consumer Financial Protection Bureau Director Rohit Chopra spoke with the Washington Post regarding the banking industry after the failure of Silicon Valley Bank. Director Chopra, who is also a board...more
As outlined in our previous client alert relating to the current banking environment in the wake of SVB's failure and FDIC receivership, and notwithstanding the apparent stabilization of the banking industry and financial...more
On Monday March 13, 2023, the Bank of England announced that Silicon Valley Bank UK Limited has been sold to HSBC UK Bank Plc. The situation remains fluid, and the following Q&A reflects our understanding as of Monday...more
On March 10, 2023, the California Department of Financial Protection and Innovation announced that it had closed down Silicon Valley Bank (“SVB”), a financial institution known for its services to start-ups and the venture...more
On February 15th, the Federal Deposit Insurance Corporation (FDIC) issued another round of cease-and-desist letters demanding that companies stop making false and misleading statements regarding deposit insurance coverage....more
On February 15, the FDIC sent letters to four entities demanding that they stop making false or misleading representations about FDIC deposit insurance. Letters were sent to a cryptocurrency exchange and to a nonbank...more
Federal Reserve Issues Policy Statement on Section 9(13) of the Federal Reserve Act - On January 27, the Federal Reserve issued a policy statement interpreting section 9(13) of the Federal Reserve Act, which authorizes...more
The Federal Reserve has adopted a final rule that provides benchmark replacement rates based on SOFR (Secured Overnight Financing Rate) for contracts governed by U.S. law that reference the overnight and one-, three-, six-,...more