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Sheppard Mullin Richter & Hampton LLP

Fintech Industry Trade Associations Respond to Federal Regulators’ Joint RFI on Bank-Fintech Partnerships

On October 30, two leading fintech industry trade associations submitted comments (see comment letters here and here) in response to a joint Request for Information (RFI) issued by the Office of the Comptroller of the...more

GeoDataVision

Have Regulators Already “Raised the Bar” for CRA Exams?

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When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA performance ratings are in it...more

Troutman Pepper

FDIC Extends Comment Period for Proposed Changes to Brokered Deposit Regulations

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Yesterday, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter- October 2024 # 2

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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

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

Troutman Pepper

Where the F(BO) is the Money? Part 2 — Adopting the Right Lessons from Synapse

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This is the second 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 - September 2024 #4

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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

Ballard Spahr LLP

FDIC board approves NPRM that would increase recordkeeping for 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

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 and OCC Finalize New Guidelines on Bank Mergers

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Yesterday, both the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) finalized new guidelines regarding bank mergers. According to the agencies, these updates aim to enhance...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

Katten Muchin Rosenman LLP

Basel III Endgame: Will Banks Have to Increase Their Capital Requirements?

On Tuesday, September 10, the Federal Reserve announced a reproposal of the much discussed and awaited Basel III Endgame. However, before we dive into the reproposal, it is important to take a step back and look at how we got...more

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

Ballard Spahr LLP

Defendant Challenges FDIC Enforcement Proceeding, Citing Jarkesy

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In one of the first tests of the implications of the Jarkesy decision for other federal regulatory agencies, an individual accused by the FDIC of participating in fraudulent loan activity is asking a federal judge to dismiss...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024 # 4

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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

Troutman Pepper

FDIC Proposal on Change-in-Control Notices Has Potential Ripple Effects on M&A

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Some advisers suggested the bank regulatory agencies could join forces without this proposed rule, though they have not always coordinated on various works in the past. Although the agencies could collaborate informally,...more

Troutman Pepper

Brokered Deposits Rule Threatens to Upend Bank Balance Sheets

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“In the worst case, these [newly designated brokered deposits] will have to get offloaded in a way that potentially puts those banks at even greater liquidity risk, especially to the extent that they have a higher...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

Venable LLP

FDIC Rethinks Brokered Deposits, Again

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The FDIC recently proposed a rule that would substantially change the 2020 final rule on brokered deposits that largely liberalized the FDIC’s framework. The proposed rule would eliminate many of the changes from 2020 and...more

Ballard Spahr LLP

FDIC Seeking Comments on Industrial Bank Rule Changes

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The FDIC is seeking comment on proposed changes to its regulation governing parent companies of industrial banks and industrial loan companies—Part 354 of the FDIC Rules and Regulations....more

Troutman Pepper

Bank Allies Say FDIC Brokered Deposit Plan Reflects Outdated Thinking

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“Hot money” – as it was later dubbed – was viewed by skeptics as one of the major causes of the savings and loan crisis of the 1980s....more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024

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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

Mayer Brown

Regulatory Redux: FDIC Proposes Brokered Deposit Revisions

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On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...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

Troutman Pepper

Turning Back the Clock: FDIC Proposes Significant Changes to 2020 Brokered Deposit Rule

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On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s...more

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