Deposit Account Litigation: Highlights From 2024 and What to Expect in 2025 — The Consumer Finance Podcast
Recently, U.S. attorneys general from 32 states and territories authored a bipartisan letter urging Congress to advance the SAFER Banking Act of 2025, which would increase access to regulated banking and financial services...more
The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder....more
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
This is the first in a series of articles in our "So, You Want to Be a Bank?" series. More than 1,000 new banks were formed in the eight years before the Great Recession began in 2008. In comparison, the past 15 years...more
On March 20, the Office of the Comptroller of the Currency (OCC) announced that it will no longer examine its regulated institutions for reputation risk. According to the OCC’s “Categories of Risk,” reputation risk is the...more
Saying that its proposed brokered deposits rule would have “significantly disrupted many aspects of the deposit landscape,” the FDIC has withdrawn the proposal. ...more
In this episode of The Consumer Finance Podcast, Chris Willis is joined by Mary Zinsner and Heryka Knoespel, partners in Troutman Pepper Locke’s Consumer Financial Services Practice Group, to discuss the latest in deposit...more
On January 8, the United States District Court for the Southern District of New York dismissed the claims brought by Banco San Juan Internacional, Inc. (BSJI) against the Federal Reserve Bank of New York (FRBNY) and the Board...more
Our Financial Services Group unpacks the Consumer Financial Protection Bureau’s final rule on consumer financial data rights under Section 1033 of the Dodd–Frank Act....more
The percentage of unbanked households in the U.S. fell to its lowest level in 2023—4.2%–, the FDIC recently reported....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
The next installment in McGlinchey’s Deep Dive into Bank Partnerships Series features an overview of depository services, featuring insights from our attorneys Rachael Aspery, Brian Fink, and Aaron Kouhoupt. They explore key...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
On October 22, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final rule implementing Section 1033 of the Dodd-Frank Act (the “Final Rule” or the “Open Banking Rule”), granting consumers greater access...more
The Situation: On September 17, 2024, the Federal Deposit Insurance Corporation ("FDIC") approved a proposed rule ("the Proposal") that would establish new recordkeeping requirements for FDIC-insured depository institutions...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
On September 17, 2024, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) issued final “statements of policy” for transactions subject to the Bank Merger Act (“BMA”)....more
Recently, the Fed issued an RFI and comment period on the operational aspects of the discount window and the provision of intraday credit to banks and credit unions. The discount window allows depository institutions to...more
On September 17th, the Federal Deposit Insurance Corporation ("FDIC") issued a proposed rule entitled “Recordkeeping for Custodial Accounts” with comments due sixty days from the date of publication in the Federal Register...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
On July 30, 2024, the Federal Deposit Insurance Corporation (“FDIC”) Board of Directors approved a final rule that updates the FDIC’s regulations concerning Section 19 of the Federal Deposit Insurance Act, 12 U.S.C.§ 1829...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
The Federal Deposit Insurance Corporation (FDIC) has revised its regulations on Section 19 of the Federal Deposit Insurance Act to conform with the previously enacted Fair Hiring in Banking Act (FHBA). The FHBA paved the way...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