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Rulemaking Process Federal Deposit Insurance Corporation Banks

Cadwalader, Wickersham & Taft LLP

Global Moves, Digital Shifts, July 2025 - Fed, FDIC and OCC Issue Proposed Rulemaking to Rescind 2023 CRA Rule

Last week, the Federal Deposit Insurance Corporation (“FDIC), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”)  issued a proposed rulemaking to both...more

Orrick, Herrington & Sutcliffe LLP

FDIC submits changes to bank establishment and relocation rules

On July 15, the FDIC Board approved a notice of proposed rulemaking to streamline processes related to the establishment and relocation of domestic branches and offices. The FDIC’s stated its objective is to reduce the...more

Sheppard Mullin Richter & Hampton LLP

Fintech Industry Trade Associations Respond to Federal Regulators’ Joint RFI on Bank-Fintech Partnerships

On October 30, two leading fintech industry trade associations submitted comments (see comment letters here and here) in response to a joint Request for Information (RFI) issued by the Office of the Comptroller of the...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

Bradley Arant Boult Cummings LLP

New FDIC Recordkeeping Requirements: Director Chopra Cautions Against a New Form of “Rent-a-Bank”

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) rulemaking board proposed new recordkeeping rules intended to bolster the FDIC’s ability to make deposit insurance determinations for accounts that are...more

Troutman Pepper Locke

FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core

Troutman Pepper Locke on

“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more

Sheppard Mullin Richter & Hampton LLP

Persisting Regulatory Uncertainty: Federal Regulators Delay New Community Lending Rules

On March 21, the FDIC, Fed, and OCC jointly issued an interim final rule to extend the applicability date of certain provisions of the Community Reinvestment Act (CRA) final rule and requested comments on the extension. The...more

Ballard Spahr LLP

The New CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 3

Ballard Spahr LLP on

This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 2

Ballard Spahr LLP on

This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Goodwin

Banking Agencies Finalize Community Reinvestment Act Rules

Goodwin on

On October 24, 2023, the Board of Governors of the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the Agencies) approved long-awaited final...more

Goodwin

Federal Reserve and FDIC Solicit Public Comments on Proposed Rulemaking Addressing Large Banks’ Financial Stability

Goodwin on

Regulatory Developments - Federal Reserve and FDIC Solicit Public Comments on Proposed Rulemaking Addressing Large Banks’ Financial Stability - On October 14, the Federal Reserve and the FDIC published for public...more

Cadwalader, Wickersham & Taft LLP

Bank Trade Associations Criticize FDIC Deposit Insurance Assessment Rate Proposal

As we previously wrote in June, the Federal Deposit Insurance Corporation (“FDIC”) proposed amendments to the Deposit Insurance Fund (“DIF”) restoration plan originally adopted in September 2020 to implement a universal...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Ballard Spahr LLP

House Financial Services Committee announces January hearings on CRA, “rent-a-bank schemes,” mobile payments

Ballard Spahr LLP on

The House Financial Services Committee has announced that it will hold the following hearings this month: On January 14, the Subcommittee on Consumer Protection and Financial Institutions will hold a hearing entitled, “The...more

Ballard Spahr LLP

Response from community groups to OCC/FDIC joint CRA proposal

Ballard Spahr LLP on

While banks, community groups, and regulators all seem to agree that there is a need to reform the Community Reinvestment Act (the “CRA”), which was signed into law by Jimmy Carter back in 1977 and hasn’t received a major...more

Ballard Spahr LLP

OCC and FDIC issue joint proposal to revise CRA regulations

Ballard Spahr LLP on

The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA).  Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join...more

Ballard Spahr LLP

CFPB releases more overdraft program data as a prelude to likely rulemaking

Ballard Spahr LLP on

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.” The report is based on account-level and...more

Ballard Spahr LLP

FDIC regional offices issue UDAP guidance on continuous overdraft fees

Ballard Spahr LLP on

Based on the CFPB’s rulemaking agenda issued in December 2013, we continue to expect overdraft programs to be the subject of another CFPB white paper and/or an advance notice of proposed rulemaking this year. (In June 2013,...more

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