Deposit Account Litigation: Highlights From 2024 and What to Expect in 2025 — The Consumer Finance Podcast
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 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
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
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
Components of the U.S. Federal Reserve System recently prevailed in two lawsuits in which both plaintiffs – Custodia Bank and PayServices Bank – alleged the defendants were required to grant the plaintiffs’ master account...more
A U.S. District Court recently rejected arguments that banks and institutions with novel charters have a statutory right to obtain a Federal Reserve master account. Master accounts let institutions access key parts of the...more
At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more
On January 24, the Federal Reserve announced that its program created to protect liquidity following a period of financial stress last spring, named the Bank Term Funding Program (BTFP), will stop making loans on March 11....more
On October 6, the Fed approved a final rule to implement a rule establishing capital requirements for insurers it supervises. The final rule includes the Building Block Approach (BBA) framework, which is a regulatory...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
On July 28, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (NCUA)...more
Consumers and businesses stand to benefit from rapid access to funds at any time when routed through participating financial institutions. On July 20, 2023, the Federal Reserve announced the long-awaited launch of its...more
On April 28, 2023, the Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Federal Deposit Insurance Corporation (“FDIC”) each released reports detailing the respective agency’s supervision history...more
Congress will be “starting from scratch” in attempting to establish a regulatory framework for stablecoins — an issue that many believe is the top digital asset legislative priority. On April 15, 2023, the US House...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
A little over a week has passed since the Federal Deposit Insurance Corp. (FDIC) became receiver of Silicon Valley Bank (SVB) and Signature Bank (Signature), and since the issuance of the joint statement by the FDIC, the U.S....more
This week the Federal Reserve reported that its instant payment service, FedNow, will be available for all participating financial institutions to use starting in July 2023....more
Regulatory Developments - The U.S. Government Takes Action on the Silicon Valley Bank and Signature Bank Failures - On March 12, the FDIC, the Federal Reserve, and the U.S. Treasury Department announced that the U.S....more
As we noted very briefly on Monday in our “Quick Take on a Sudden Change in the Banking Landscape,” among the various actions the government took Sunday evening to try to stabilize the banking market, the Federal Reserve...more
Since Friday, March 10, 2023, more than 300 public companies have filed current reports on Form 8-K regarding the closure of Silicon Valley Bank ("SVB"). Company disclosure in these 8-Ks falls essentially into four...more
On Sunday evening, March 12, 2023, two extraordinary joint press releases were simultaneously issued by the U.S. Department of Treasury, the Federal Reserve Bank, and the Federal Deposit Insurance Corporation (FDIC). The...more
On Friday, March 10, 2023, the California Department of Financial Protection & Innovation, aided by the Federal Deposit Insurance Corporation (“FDIC”) shuttered Silicon Valley Bank (“SVB”) over concerns surrounding its...more
On Friday, March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank ("SVB") and the Federal Deposit Insurance Corporation ("FDIC") was appointed SVB's receiver....more