News & Analysis as of August 15, 2025

Bank Holding Company

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The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s. The FDIC's mission is to maintain stability and consumer confidence in the United States banking system by insuring deposits, monitoring the health of financial institutions and managing receiverships. less -

Consequences of Forming or Acquiring a Depository Institution

Goodwin on 5/7/2025

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

FDIC releases NPRM for parent companies of industrial entities

Orrick, Herrington & Sutcliffe LLP on 8/8/2024

On July 30, the FDIC released an NPRM to regulate parent companies of industrial banks and industrial loan companies (the industrial entities). The proposed rule would revise the definition of “Covered Company” to include...more

An Introduction to the Unique Issues in Bank Holding Company Bankruptcies

Skadden, Arps, Slate, Meagher & Flom LLP on 3/20/2023

On March 17, 2023, the parent of Silicon Valley Bank (SVB) filed for Chapter 11 protection in the Southern District of New York. Unlike SVB itself, its parent, as a bank holding company, was eligible for Chapter 11. In the...more

Democratic Senators introduce bill to close industrial loan company “loophole”; coalition of financial services and consumer...

Ballard Spahr LLP on 12/8/2022

Earlier this week, Senator Sherrod Brown (D-Ohio) introduced a bill, the “Close the Shadow Banking Loophole Act,” (Act) that is intended to close what is often termed a “loophole” in the Bank Holding Company Act (BHCA)...more

Promissory Notes - Banking & Finance Insights: Issue 12, December 2022

Spilman Thomas & Battle, PLLC on 12/7/2022

US Senators Ask SoFi About Its Banking Law Compliance = “Four U.S. senators have signed a letter to SoFi Technologies CEO Anthony Noto expressing concerns about the online personal finance company and online bank’s digital...more

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

Troutman Pepper on 10/20/2015

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

LCR – The Fed Takes Tentative Step to Expand HQLAs

Morrison & Foerster LLP on 6/2/2015

When the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”) and the Federal Deposit Insurance Corporation (the “FDIC”) finalized the Liquidity Coverage...more

Federal Banking Agencies Issue Final Version of Addendum to Interagency Policy Statement on Income Tax Allocation

Goodwin on 6/25/2014

The FRB, FDIC and OCC (collectively, the “Agencies”) issued a final version of an addendum (the “Addendum”) to their “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure” (the “Policy...more

Bank Regulators Require Changes To Tax Allocation Agreements

Dickinson Wright on 6/18/2014

Acting in response to divergent results in recent court decisions, the Federal bank regulatory agencies have adopted an Addendum to their longstanding rules regarding income tax allocation agreements between insured...more

FRB, FDIC and OCC Issue Final Rule Regarding Leverage Ratios for Largest Top-Tier Bank Holding Companies

Goodwin on 4/18/2014

On April 8, 2014, the FRB, FDIC and OCC (collectively, the “Agencies”) released a final rule (the “Final Rule”) concerning the leverage ratio standards for large, interconnected U.S. banking organizations. The Final Rule...more

Observation 1.1 On The Volcker Rule: Community Banks – Size Does Matter

Troutman Pepper on 12/24/2013

On December 10, 2013, after more than three years of intensive development, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation...more

Liquidity Coverage Ratio Impact on Covered Bonds

Morrison & Foerster LLP on 12/3/2013

On October 23, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Agencies”) published a notice of proposed rulemaking...more

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