Reg. CC-Funds Availability, it ’s a good time to revisit the hold provisions and timing for Reg. CC.
On July 30, the FDIC released an NPRM that would provide restrictions, update definitions, and provide new exceptions to the rule on brokered deposits. The FDIC explained that these proposed amendments would simplify...more
On July 30, the FDIC released an RFI for deposit data, specifically data not reported in the Federal Financial Institutions Examination Council’s (FFIEC) call reports or other regulatory reports. The FDIC is seeking comments...more
“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
On March 13, the Governor of Washington State signed into law SB 5801, enshrining a new chapter titled the Uniform Special Deposits Act. The law will apply to special deposits under account agreements that intend to establish...more
In episode 64 of the Compliance 911 podcast, hosts Len Suzio and Dean Stockford discuss the intricacies of Reg. CC, a regulation that deals with funds availability. Dean emphasizes the importance of understanding the...more
Now is the Time to Guard Against Reckless Banking Legislation - “Only a structural change to the way Congress acts on financial regulation will prevent future losses.” Why this is important: An old adage is that...more
Background- On March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank (SVB) and appointed the Federal Deposit Insurance Corporation (FDIC) as receiver for SVB....more
In January 2020, we wrote a Law360 guest article that highlighted some of the risks that followed Wells Fargo Bank NA's strategy in its patent dispute with the United Services Automobile Association over remote deposit check...more
This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more
United States Automobile Association (USAA) is a financial services company that provides insurance, banking, investment, and retirement products and services for members of the military and their families. On June 7, 2018,...more
FDIC and OCC Propose CRA Modernization Rule with Opt-Out for Small Banks The FDIC and the OCC have jointly proposed amendments to modernize the agencies’ Community Reinvestment Act (“CRA”) regulations, which are intended...more
This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more
Over the years USAA has aggressively asserted its patent portfolio related to check depositing. Specifically, USAA holds itself out as an innovator in the research and development of allowing banking customers to deposit...more
More than three years after proposing amendments to Regulation CC to add new indemnities for remotely deposited checks, new warranties for electronic checks and electronic returned checks, and new indemnities for...more
Jean-Claude Juncker, President of the European Commission, has announced that the Commission will publish a legislative proposal on first steps towards establishing a common deposit guarantee system by the end of 2015. His...more