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McGlinchey Stafford

CFPB to Reopen 1033 Open Banking Rulemaking

McGlinchey Stafford on

The Consumer Financial Protection Bureau’s (CFPB) open banking rules, issued under Section 1033 of the Dodd-Frank Act, have been the subject of ongoing litigation since their finalization late last year. The litigation is...more

GeoDataVision

Potential Improvements for CRA (Part 4c of 4)

GeoDataVision on

In the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I...more

Orrick, Herrington & Sutcliffe LLP

House Financial Services Committee chair urges regulatory changes for CFPB and prudential regulators

On April 1, the Chairman of the U.S. House Committee on Financial Services, Rep. French Hill (R-AR) released nine letters they sent to the heads of the FDIC, the OCC, the Fed, the CFPB, the SEC, and the Federal Stability...more

Orrick, Herrington & Sutcliffe LLP

FDIC receives letter from senators to finalize its custodial accounts rule

On January 16, the FDIC received a letter from Sens. Ron Wyden (D-OR) and John Fetterman (D-PA) urging the finalization of a proposed rule to strengthen recordkeeping for custodial accounts. As previously covered by...more

Goodwin

What’s Next for Fintechs in 2025? Key Regulatory Developments to Watch

Goodwin on

With the start of the new year comes new regulatory priorities, regulatory challenges, and regulatory opportunities for fintechs. Below, we lay out considerations for 2025 given the change in administration and accompanying...more

Jones Day

FDIC Proposes New Requirements for Custodial Accounts to Qualify for Pass-Through

Jones Day on

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

Cadwalader, Wickersham & Taft LLP

The FDIC’s Proposed “Synapse” Rule Affects Deposit Accounts Opened by Fintech Custodians

On September 17th, the Federal Deposit Insurance Corporation ("FDIC") issued a proposed rule entitled “Recordkeeping for Custodial Accounts” with comments due sixty days from the date of publication in the Federal Register...more

Fenwick & West LLP

FDIC Proposes More Oversight on Custodial Deposit Accounts

Fenwick & West LLP on

On September 17, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would significantly impact the risk management and oversight requirements for bank-fintech arrangements. This proposal comes in...more

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

Venable LLP on

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

Venable LLP

Banking on a Nonbank Bank in 2024 - The ILC Option Revisited

Venable LLP on

Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more

Cooley LLP

FDIC’s Proposed Brokered Deposit Rule Could Adversely Impact Fintech-Bank Partnerships

Cooley LLP on

In late July 2024, the Federal Deposit Insurance Corporation (FDIC) board of directors proposed a rule that would revise its standards on banks accepting brokered deposits. The proposed rule would expand the definition of...more

Jenner & Block

Client Alert: The CFPB’s New “Open Banking” Rule: Consumers and Competition Expected to Win Once Policies and Procedures Ironed...

Jenner & Block on

Last week, the Consumer Financial Protection Bureau issued its long-awaited proposed rule to implement Section 1033 of the 2010 Consumer Financial Protection Act, which has come to be known as the “open banking” provision...more

Seward & Kissel LLP

Proposed FDIC Rule Would Impose Additional Deposit Insurance Disclosure Obligations on Banks and Non-Banks

Seward & Kissel LLP on

The Federal Deposit Insurance Corporation (“FDIC”) published for comment in December 2022 a notice of proposed rulemaking (12 CFR Part 328) (“Proposed Rule”) that would apply to all FDIC-insured institutions and impose new...more

Perkins Coie

Fintech Legal Report - September 2021

Perkins Coie on

Federal Banking Agencies Issue Guide for Community Banks on Conducting Due Diligence on Fintech Companies - On August 27, 2021, the federal banking agencies (Federal Reserve, FDIC, and OCC) published “Conducting Due...more

Goodwin

CFPB Withdraws Proposal to Delay Debt Collection Final Rules

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more

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