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Federal Deposit Insurance Corporation Risk Management

The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s.  The FDIC's mission is to maintain... more +
The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s.  The FDIC's mission is to maintain stability and consumer confidence in the United States banking system by insuring deposits, monitoring the health of financial institutions and managing receiverships.  less -
Troutman Pepper

Where the F(BO) Is the Money? Part 1 – Synapse’s Clarion Call for Standards

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This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Orrick, Herrington & Sutcliffe LLP

GOP Senators express concern on FDIC proposed rules regarding corporate governance and risk management

On July 31, Republican members of the U.S. Senate penned a letter to the Chairman of the FDIC, Martin Gruenberg, to convince the Chairman that an FDIC proposed rule regarding soundness standards for corporate governance and...more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Alston & Bird

Regulators Focus on Bank-Fintech Arrangements

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Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team...more

Troutman Pepper

FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core

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“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

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2024

The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more

Ballard Spahr LLP

Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions

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The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

McGlinchey Stafford

Bank Partnerships in an Evolving World

McGlinchey Stafford on

Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

Goodwin on

As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Poyner Spruill LLP

The First Bank to Collapse in 2024: What Led to the Failure of Republic Bank

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The first bank to meet its demise in 2024 is smaller than its 2023 counterparts. In 2023 we saw Silicon Valley Bank (“SVB”) and First Republic Bank (“First Republic”) fail. The most recent bank to experience a failure bears a...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Curb Incentive-Based Compensation in the Financial Services Industry

Latham & Watkins LLP on

The proposal seeks to make executive compensation arrangements more sensitive to risk and would require complex risk management programs to ensure compliance....more

Skadden, Arps, Slate, Meagher & Flom LLP

The Third Attempt: Banking Agencies Revive Incentive-Based Compensation Rules for Financial Institutions

The Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and the National Credit Union Administration (NCUA) recently re-proposed rules...more

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

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It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

Orrick, Herrington & Sutcliffe LLP

Fed, OCC, and FDIC release third-party risk management report for community banks

On May 3, the Fed, OCC, and FDIC (the regulators) released a report to help community banks assess their third-party relationship risk exposure. The report discusses key considerations in three areas: risk management,...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more

Troutman Pepper

FDIC Announces Two More Consent Orders Containing Third-Party Risk Management and Fintech Partnership Orders

Troutman Pepper on

On March 29, the Federal Deposit Insurance Corporation (FDIC) announced two more consent orders containing provisions relating to banks’ third-party risk management programs with respect to banking as a service (BaaS)...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - March 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 3

Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Sheppard Mullin Richter & Hampton LLP

FDIC Issues Consent Order Against Tennessee Bank

On January 30, a Tennessee-based community bank entered into a consent order with the Federal Deposit Insurance Corp. following the agency’s allegations that the Bank engaged in unsafe or unsound banking practices relating to...more

Kramer Levin Naftalis & Frankel LLP

The 2023 SNC Review Results: Increased Critical Loans Observed

On Feb. 16, 2024, the board of governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and together with the...more

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