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FDIC Issues Narrow Interpretation of ATM Exception in Definition of Domestic Branch

On August 9, 2024, the US Federal Deposit Insurance Corporation (FDIC) issued an interpretation of the exclusion of automated teller machines (ATMs) and remote service units (RSUs) from the definition of a domestic branch....more

The Pendulum Swings Back: FDIC Proposes Changes to Brokered Deposits Restrictions

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s...more

Federal Reserve Wins Two Master Account Lawsuits

At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more

What to Expect in Banking in 2024

The end of 2023 saw a barrage of major proposals and other actions by US banking regulators. Many of these are contentious issues that have divided regulators and generated significant public controversy. Final proposals of...more

Impact of the Banking Crisis on Bank-FinTech Relationships

The recent banking crisis has highlighted the need for FinTechs to take a strategic approach to their current and future bank partner relationships. With bank regulators focusing their attention on exactly these types of...more

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