News & Analysis as of August 12, 2025

Financial Institutions

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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 -

Prudential regulators release 2024 Shared National Credit report

Orrick, Herrington & Sutcliffe LLP on 3/17/2025

On March 10, the FDIC, the Fed and the OCC published the 2024 Shared National Credit Program (SNC) report which highlighted that the overall SNC credit risk remains moderate — with a slight increase in the severity of risk...more

U.S. Financial Regulators Continue Focus on Bank-Fintech Partnerships through Guidance and Request for Information

Pillsbury - Global Sourcing Practice on 9/6/2024

On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential...more

Bank Partnerships in an Evolving World

McGlinchey Stafford on 7/19/2024

Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

Ballard Spahr LLP on 5/8/2024

On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Recent FDIC consent orders show increased regulation scrutiny of bank relationships with fintech partners

Ballard Spahr LLP on 4/10/2024

In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

Latham & Watkins LLP on 11/8/2023

Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

FRB Vice Chair for Supervision Recommends Stronger Capital Standards for Large US Banks

Latham & Watkins LLP on 7/21/2023

After a lengthy “holistic” review and a spring banking crisis, US bank capital requirements finally face overhaul. On July 10, 2023, US Federal Reserve Board (FRB) Vice Chair for Supervision Michael Barr delivered a...more

Bank Regulators Issue Guidance for Third-Party Risk Management

Goodwin on 7/3/2023

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more

FDIC Proposes Special Deposit Insurance Assessment After Systemic Risk Exception

Cadwalader, Wickersham & Taft LLP on 5/12/2023

The Federal Deposit Insurance Corporation (“FDIC”) Board voted (3-2) to propose a special assessment to recoup the expected $15.8 billion cost to the Deposit Insurance Fund “(DIF”) in the wake of invocation of the special...more

Banking Disruption: Banking Regulators Signal Updates to Supervisory and Regulatory Agendas in Wake of Bank Failures

Morrison & Foerster LLP on 5/12/2023

On April 28, 2023, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the United States Government Accountability Office (GAO), and the New York Department of...more

FDIC Enters into Consent Order with Fintech Focused Bank

Morrison & Foerster LLP on 5/5/2023

Reflecting expected heightened regulatory scrutiny of fintech-bank partnerships, the Federal Deposit Insurance Corporation (FDIC) issued a consent order for a bank that is deep in the bank-fintech sponsorship space over...more

Strategic Considerations in the Rapidly Changing Banking Environment

Baker Donelson on 3/20/2023

On March 10, 2023, the California Department of Financial Protection and Innovation and the Federal Deposit Insurance Corporation (FDIC) closed Silicon Valley Bank (SVB) after a deposit outflow created a severe liquidity...more

Can Directors/Officers be Liable for Depositing Corporate Funds in and Borrowing from a Bank Taken Over by the FDIC?

Foley & Lardner LLP on 3/15/2023

Last week, state regulators forced Silicon Valley Bank (SVB) into receivership, and the Federal Deposit Insurance Corporation (FDIC) was appointed as receiver. SVB’s failure marks the largest receivership since Washington...more

Flurry of Announcements by the Federal Reserve on Crypto Activities

WilmerHale on 2/17/2023

A flurry of activity on January 27 signaled continued skepticism from the Federal Reserve of crypto-asset-related activities generally and open, public or decentralized networks in particular....more

Recent Actions by the Fed Show Its Continued Cautious Approach to Cryptoasset Activities by Supervised Institutions

Skadden, Arps, Slate, Meagher & Flom LLP on 2/7/2023

In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more

Banking Regulators Issue Joint Statement on Crypto Risks

Latham & Watkins LLP on 1/12/2023

Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal. On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal...more

CDD Friendly Reminder From The Agencies To The Banks

Foodman CPAs & Advisors on 8/2/2022

On 7/6/22, the Agencies (Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the...more

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on 3/14/2022

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

Nutter Bank Report: December 2021

Nutter McClennen & Fish LLP on 12/28/2021

FDIC Board Governance Dispute on Review of Bank Mergers Aired Publicly - CFPB Director Rohit Chopra on December 9 published on the CFPB’s website a blog post captioned “How Should Regulators Review Bank Mergers?” in...more

FFIEC Updates Guidance to Financial Institutions for Authentication and Access

Cozen O'Connor on 9/15/2021

The Federal Financial Institutions Examination Council (FFIEC), an interagency body of leading financial regulators, including the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency,...more

The Antitrust Risk of the Federal Banking Agencies’ Proposed Risk Management Guidance

Morgan Lewis - All Things FinReg on 9/10/2021

As highlighted previously, three federal banking agencies (the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency) recently issued proposed risk management...more

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

Goodwin on 8/20/2021

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

Enhancing Transparency in the Agencies’ Approach to BSA/AML Examinations

Moore & Van Allen PLLC on 8/6/2019

Last month the Financial Crimes Enforcement Network (FinCEN) and the federal bank regulators issued a Joint Statement aimed at improving transparency into their risk-focused examination and supervision of banks’ compliance...more

Proposed Regulatory Updates Will Require Increased Analysis of New Loans to Determine if Different Risk Weight Exposures Apply

Steptoe & Johnson PLLC on 10/31/2017

On September 27, 2017, the principal federal banking agencies, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, released a Notice of...more

OCC Establishes New Third-Party Risk Management Expectations, Including for Bank Relationships With Marketplace Lenders

Troutman Pepper Locke on 2/22/2017

The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties. On January 24, the Office of...more

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