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FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

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

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

Regulatory Redux: FDIC Proposes Brokered Deposit Revisions

On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...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

Some US Regulators Repropose Joint Rule on Incentive-Based Compensation

On May 6, 2024, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and National Credit Union Administration (NCUA; collectively the...more

How Many Digits? FinCEN Seeks Comment on Bank Customer Identification Requirements

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

Silicon Valley Bank Developments – Q&A for Startups and VCs

Q: Who runs SVB now? A: SVB has been placed in receivership by banking regulators. This receivership applies to Silicon Valley Bank and not its affiliates....more

US Agencies Proposed Revisions to Volcker Rule Covered Funds Provisions

On January 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the Office of the Comptroller of the Currency (“OCC”), the Securities and Exchange...more

FDIC Adopts Changes to Securitization Safe Harbor Rule

Since its adoption in 2010, the Federal Deposit Insurance Corporation’s (the “FDIC”) securitization safe harbor rule, 12 C.F.R. § 360.6 (the “Rule”), which relates to the treatment of financial assets transferred in...more

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