On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more
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
On May 22, 2024, the US federal banking regulators finalized a new set of reporting requirements for bank loans and commitments to fund finance facilities, private credit lenders, and other nonbank financial entities.This...more
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
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
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
On January 26, 2024, the US federal banking regulators announced proposed reporting changes to implement the Basel III Endgame requirements. This may come as a surprise to the many banking organizations and others, who only...more
On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more
1/17/2024
/ Banking Regulators ,
Banks ,
Creditors ,
FFIEC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OCC ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On December 27, 2023, the US federal banking regulators proposed reporting requirements for bank loans and commitments to the fund finance sector. This change reflects not only the rapid growth in this sector but also the...more
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and...more
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more
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
In December, the State of Iowa and the Iowa Division of Banking entered into an Assurance of Discontinuance (“AOD”) with Transportation Alliance Bank, Inc. (the “Bank”) settling claims that the Bank charged usurious rates of...more
1/13/2023
/ Assurance of Discontinuation (AOD) ,
Banks ,
Consumer Financial Products ,
Consumer Lenders ,
DIDMCA ,
Financial Services Industry ,
Interest Rates ,
Internet Lenders ,
Opt-Outs ,
Settlement Agreements ,
True Lender ,
Usury
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related...more