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Foreign Banking Organizations Comment Period

Fenwick & West LLP

FDIC Proposes More Oversight on Custodial Deposit Accounts

Fenwick & West LLP on

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

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

Venable LLP on

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

Morrison & Foerster LLP

TLAC, and Then Some… A Preliminary Assessment of the Federal Reserve Board’s NPR

On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...more

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