Consumer Finance Monitor Podcast Episode: How a Former FDIC Chairman is Reacting to the Silicon Bank Valley Failure, A Discussion with Special Guest Bill Isaac, Chairman, Secura/Isaac Group, and FDIC
Making Cents of Your Cash Management Agreements
In early March, nearly a year and a half after it was initially proposed, the Massachusetts Attorney General's Office finalized the Commonwealth's "junk fee" regulation (the "Final Rule") while simultaneously issuing a...more
Bill 72, An Act to protect consumers against abusive commercial practices and to offer better transparency with respect to prices and credit, was recently tabled by the Québec government. This legislation includes amendments...more
Bermuda is enhancing its banking legislation to make it attractive to new banks – particularly those wishing to provide services to Fintech companies. The new 'restricted banking' license makes it easier to set up in...more
The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more
On September 17th, the Federal Deposit Insurance Corporation ("FDIC") issued a proposed rule entitled “Recordkeeping for Custodial Accounts” with comments due sixty days from the date of publication in the Federal Register...more
On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more
On 18 September 2024, the FCA provided an update on its work in the cash savings market. Following the FCA’s 2023 cash savings market review in light of concerns that higher interest rates were not being passed on effectively...more
Our Financial Services Team studies the Federal Deposit Insurance Corporation’s plans to require insured depository institutions (IDIs) to keep specific records so that they know the actual owner of deposits placed by...more
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
As a lending lawyer for more than a quarter century at this point, I have seen that deposit accounts and deposit account control agreements are a routine component of virtually every transaction. Deposit accounts are a source...more
The Federal Deposit Insurance Corporation (“FDIC”) proposed in its Notice of Proposed Rulemaking (“NPR”) that insured IDIs keep records of individual accounts that are typically held in pooled custodial accounts that support...more
The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more
On September 17, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would significantly impact the risk management and oversight requirements for bank-fintech arrangements. This proposal comes in...more
The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more
In what should come as no surprise to FinTech sponsor banks, the FDIC is reemphasizing the need to maintain control over synthetic account ledgers in the wake of the Synapse collapse. On September 17, the FDIC's rulemaking...more
On September 11, 2024, the CFPB issued an administrative consent order against the Bank, alleging multiple violations of the Fair Credit Reporting Act (FCRA), the Consumer Financial Protection Act (CFPA), and the Furnisher...more
On July 9, 2024, the Consumer Financial Protection Bureau (CFPB) announced that it filed a proposed stipulated final judgment and order in its suit against a national bank accused of allegedly opening unauthorized accounts...more
This CLE course will examine some of the more common pitfalls in loan restructurings that are frequently unidentified or ignored until they appear at or after closing. The panel discussion will include agency resignations,...more
In this month's article, we share some of our top "bites" covered during the May 2024 webinar....more
On March 12, the Governor of Indiana signed HB 1284 which codified a new chapter regarding a contract for a deposit account between a depository institution and a consumer may be changed occasionally, subject to the terms of...more
This past week, Indiana Governor Eric Holcomb signed H.B. 1284 and S.B. 188 into law, each of which will become effective on July 1, 2024. H.B. 1284 was authored in response to the recent Indiana Supreme Court holding in...more
The Financial Services and Markets Act 2023 (Digital Securities Sandbox) Regulations 2023 came into force on Jan. 8, creating the U.K.'s first digital securities sandbox within which firms would be able to test new...more
After an intense 2023 rulemaking, supervisory, and enforcement cycle for the federal banking agencies, the FDIC issued a final rule on FDIC official signs and advertising requirements right before the new year. The rule comes...more
Deposit Insurance - Are the deposits at my bank FDIC-insured? Deposits held at FDIC-insured depository institutions are insured up to $250,000 per depositor for deposits held in the same “right and capacity.”...more