Deposit Account Litigation: Highlights From 2024 and What to Expect in 2025 — The Consumer Finance Podcast
On June 17, 2025, the U.S. Senate passed S. 1582 (GENIUS Act) with bipartisan support (68–30), creating the first comprehensive federal framework for stablecoin regulation. This landmark legislation establishes clear...more
On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule) on personal financial data rights under Section 1033 of the Dodd-Frank Act. The Rule imposes significant new obligations on...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
In a move that has been a long time in the making, the Consumer Financial Protection Bureau (CFPB) has finalized its comprehensive open banking rule. The rule implements Section 1033 of the Dodd-Frank Act and grants consumers...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
The Federal Reserve’s Bank Term Funding Program (BTFP) will sunset as planned on March 11, ending a program that helped calm the markets after last year’s collapses of Silicon Valley Bank and Signature Bank threatened a...more
The Cozen Lens- •The state of the economy is unclear, with conflicting indicators of where it is heading. But this uncertainty isn't stopping Washington, DC from defining the economy for partisan gains. •With regional banks...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
On March 10, 2023, Silicon Valley Bank and Signature Bank were closed by their respective jurisdictions’ financial service agencies due to a high influx of depositors making massive withdrawals in the week prior....more
As we have previously discussed, after the failure of Silicon Valley Bank (“SVB”), the FDIC is operating the Silicon Valley Bridge Bank, N.A. (“Bridge Bank”) in many ways as if it’s business as usual to help preserve as much...more
In the wake of Silicon Valley Bank’s failure earlier this month, many technology companies are re-examining their treasury management programs and are considering moving cash into a variety of non-demand-deposit instruments,...more
After a tumultuous few days, Silicon Valley Bridge Bank, N.A. and Signature Bridge Bank, N.A. are open to deposit and loan customers. Early on Friday, March 10, 2023, bank regulators closed Silicon Valley Bank, the...more
The Bank of England (BoE) has announced that Silicon Valley Bank UK Limited (SVB UK) will be sold to HSBC UK Bank Plc (HSBC). This is being carried out under the aegis of the Special Resolution Regime (SRR) — a bespoke...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more
On May 17, 2021, the Federal Deposit Insurance Corporation (the “FDIC”) issued a Request for Information and Comment (the “RFI”) on Digital Assets. The FDIC is interested in getting input from all interested parties on the...more
Three California laws that affect fintech companies will go into effect on January 1, 2021. The California Consumer Financial Protection Law (CCFPL) expands the scope of the Department of Business Oversight’s (DBO) current...more
The New York Department of Financial Services has sent a letter to the institutions that it regulates requiring each such institution, by February 7, 2020, to provide to DFS a description of its “plan to address its LIBOR...more
The Situation: The Office of the Comptroller of the Currency ("OCC") has appealed a decision from the Southern District of New York that concluded that the OCC lacks the authority to grant "Fintech Charters" to nondepository...more
The European Banking Authority has published the second in a series of three opinions on the implementation of the Deposit Guarantee Scheme Directive in the EU. This opinion relates to DGS payouts. The first opinion related...more
Final TLAC Rules and Structured Products - On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding long-term debt and total loss absorbing...more
To address the increasing risk of technology failures and cyber-attacks affecting the largest banking organizations, an advance notice of proposed rulemaking titled Enhanced Cyber Risk Management Standards (the ANPR) was...more