News & Analysis as of

Federal Deposit Insurance Corporation Third-Party Financial Services Industry

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 -
Morrison & Foerster LLP

FDIC Proposes to Walk Back Key Aspects of the Brokered Deposits Rule

Morrison & Foerster LLP on

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would unwind and considerably revise parts of the FDIC’s 2020 final rule governing brokered deposits (the “Proposed Rule”). The...more

Troutman Pepper

FDIC Publishes Proposed Rule on Recordkeeping for Third-Party Deposits, Opens Comment Period

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We previously posted on the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies....more

Ballard Spahr LLP

FDIC Issues Notice of Proposed Regulations for Enhanced Recordkeeping for Third-Party Custodial Accounts

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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

Troutman Pepper

FDIC Proposes New Rule to Strengthen Recordkeeping for Third-Party Deposits

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On September 17, the Federal Deposit Insurance Corporation (FDIC) announced a notice of proposed rulemaking (Proposal) aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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 Lineage Bank Consent Order Containing Third-Party Risk Management Program and Fintech Partnership Orders

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The Federal Deposit Insurance Corporation (FDIC) recently announced a consent order with Tennessee-based Lineage Bank containing orders relating to the bank’s third-party risk management program and its financial technology...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

McGlinchey Stafford on

On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Wilson Sonsini Goodrich & Rosati

Guardrails for Bank-Fintech Partnerships: The Federal Banking Agencies Finalize Third-Party Risk Management Expectations

The Board of Governors of the Federal Reserve System (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued the long-awaited...more

Jenner & Block

Client Alert: Bank-Fintech Partnerships Update: Banking Agencies Finalize Key Risk Management Guidance

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On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more

Katten Muchin Rosenman LLP

Bank/Fin-Tech Agreements: Re-Assessment Required Given New Regulatory Guidance on Third-Party Servicing Agreements

On June 6, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Banking Agencies)...more

Baker Donelson

New Proposed Guidance on Third-Party Relationships

Baker Donelson on

On July 13, 2021, the Board of Governors of the Federal Reserve (the "Fed"), the Federal Deposit Insurance Corporation (the FDIC) and the Office of the Comptroller of the Currency (the OCC), with the Fed and the FDIC...more

Perkins Coie

Fintech Week in Review - April 2021 #2

Perkins Coie on

FDIC Consumer Compliance Supervisory Highlights Fair Lending Risks - The Federal Deposit Insurance Corporation (FDIC) has issued the March 2021 edition of its Consumer Compliance Supervisory Highlights. The publication was...more

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