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FDIC Withdraws Pending Proposed Rule on Brokered Deposits

On March 3, 2025, the Federal Deposit Insurance Corporation (“FDIC”) withdrew its pending proposed rule on brokered deposits (the “Proposal”), originally published in the Federal Register on August 23, 2024. The Proposal,...more

Important Reminder About State-Chartered Credit Union Restrictions

During the past 12-18 months, we have noted a significant increase in the number of brokers underwriting share certificates issued by credit unions. It is vital for brokers in the credit union share certificate market to...more

Credit Union Share Certificates: A Primer

Over the last several years credit unions have sought to raise funds in the capital markets by issuing their Share Certificates through brokers or other intermediaries. Credit union shares have many of the same attributes of...more

S&K Observations and Practical Recommendations on Wire Transfer Fraud

Risk Trend - This risk alert highlights a recent trend of criminals using fraudulent wire transfer schemes to target financial institutions and the steps that clients can take to mitigate this increasing risk. We have...more

Bank Failure: Background and Issues to Consider

As with any business, a bank can become insolvent. But unlike most businesses, your bank holds your money or your customers’ money, making insolvency particularly fraught. On Friday, March 10, 2023, the California Department...more

What to Expect When You’re Expecting (Your Bank to Fail)

As with any business, a bank can become insolvent. But unlike most businesses, your bank holds your money or your customers’ money, making insolvency particularly fraught. In recent days, the parent corporation of Silvergate...more

2022 Highlights from the Global Bank and Institutional Finance & Restructuring Group

$55B CLO/ Loan Facilities Represented several financial institutions in connection with CLOs (including middle-market CLOs), multi-currency loan facilities and warehouse transactions, as well as redemptions, re-pricings,...more

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

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

Open Banking is Coming to America

On October 27, 2022, the Consumer Financial Protection Bureau (“CFPB”) announced a new regulatory framework (“Framework”) governing “Personal Financial Data Rights,” or, by another name, “open banking.” Conceptually, open...more

FDIC Adopts Rule Prohibiting Misleading Statements About FDIC Insurance that Impacts a Broad Range of Deposit Placement...

Introduction - On May 17, 2022, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) adopted a final rule (“Rule”) setting forth its procedures for investigating and enforcing false advertising,...more

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