Deposit Account Litigation: Highlights From 2024 and What to Expect in 2025 — The Consumer Finance Podcast
The Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”), which would comprehensively regulate stablecoins in the United States, was adopted by the U.S. Senate on June 17 by a bipartisan...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more
Financial technology — or fintech — companies will continue to receive increased regulatory scrutiny in 2025. The latter half of 2024 saw a rise in regulatory guidance and enforcement activity relating to fintechs and 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brokered deposits rule would have “significantly disrupted many aspects of the deposit landscape,” the FDIC has withdrawn the proposal.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
Oregon may become the latest state attempting to stop out-of-state banks from “exporting” home-state interest rates on loans made to Oregon consumers. Like similar legislation adopted by Colorado in 2023, House Bill 2561...more
The percentage of unbanked households in the U.S. fell to its lowest level in 2023—4.2%–, the FDIC recently reported....more
What Happened? On October 3, 2024, the CFPB released a Nonbank Registration: Orders Rule Coverage Chart (the “Chart”) that summarizes how an entity that is subject to an order may determine if it must register that order...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 Federal Deposit Insurance Corporation (FDIC) announced a proposed rule that would revise brokered deposit regulations promulgated under Section 29 of the Federal Deposit Insurance Act....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
In a proposed rule and information request, the Federal Deposit Insurance Corporation expressed its concerns with the current brokered deposit restrictions and reporting requirements. Our Financial Services Team zeroes in on...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
On June 18, 2024, in NAIB, et al v. Weiser, et al., the United States District Court for the District of Colorado granted the motion for preliminary injunction filed by plaintiffs, the National Association of Industrial...more
In 1980, Congress passed Public Law 96-221, called the Depository Institutions Deregulation and Monetary Control Act (“DIDMCA”), which, in part, allowed federally insured state banks, state credit unions, and state savings...more
The New York Department of Financial Services (“NYDFS”) has brought action in Federal court against Citibank, N.A., alleging that the bank systemically failed to protect accountholders from rampant online scam activity,...more
This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...more
Recently, the Federal Deposit Insurance Corporation (“FDIC”) released its annual Summary of Deposits (“SOD”) data, as of June 2023. The annual SOD data is the result of the FDIC’s annual survey of branch office deposits...more
Following the disruption in the market in March of this year, with the FDIC seizing three major middle-market lenders one of the questions on many people’s minds was – where were our bankers, colleagues, clients and friends...more
The FDIC set up the SVB bridge bank on March 26, which meant that Q1 bank earnings reports and industry data largely reflected a business environment that had ceased to exist by the time the numbers hit the tape. With the Q2...more
On July 28, the OCC, FDIC, NCUA and Fed issued an addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management, issued in 2010. The update on liquidity risks and contingency planning emphasizes that...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
The Federal Deposit Insurance Corporation (“FDIC”) issued a Financial Institution Letter (“FIL”) earlier this week regarding banks’ errors in reporting estimated uninsured deposits....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