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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

Ballard Spahr LLP on

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

Cadwalader, Wickersham & Taft LLP

From Albufeira to Asheville September 2024 - Evolving Perspectives on Bank Deposits

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

Hudson Cook, LLP

CFPB Bites of the Month - May 2024 - CFPB: Light My Way, Virginia May

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In this month's article, we share some of our top "bites" covered during the May 2024 webinar....more

Orrick, Herrington & Sutcliffe LLP

Indiana enacts HB 1284 regarding change in terms for deposit accounts

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

BCLP

FCA’s Cash Savings Market Review

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On 31 July 2023, following roundtable discussions held with banks earlier that month, the FCA published its Cash Savings Market Review (the “Review”). In this insight we explore the content of the Review, as well as...more

Ballard Spahr LLP

CFPB issues circular on reopening closed deposit accounts

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The CFPB has issued a circular that addresses the reopening of closed deposit accounts (Circular 2023-02).  Specifically, the circular warns that it can constitute an unfair act or practice for a financial institution to...more

Morgan Lewis

Common Cash Management Practices and Associated Protections and Risks

Morgan Lewis on

In the wake of the Silicon Valley Bank and Signature Bank defaults, it is important for bank customers to understand the common cash management options and accounts available in financial institutions as well as their...more

Cadwalader, Wickersham & Taft LLP

FDIC Vice Chair Hill Speaks on Recent Bank Failures

Federal Deposit Insurance Corporation (“FDIC”) Vice Chair Travis Hill gave a speech earlier this week, titled “Recent Bank Failures and the Path Ahead,” at the Bipartisan Policy Center. The speech appears to be Vice Chair...more

Cadwalader, Wickersham & Taft LLP

Congressional Hearings Calling Federal Regulators to Task for Recent Bank Failures

Both the Senate Banking Committee and House Financial Services Committee held hearings this week on the federal regulatory response to the failures of Silicon Valley Bank (“SVB”) and Signature Bank. Witnesses at both hearings...more

Cadwalader, Wickersham & Taft LLP

SVB Financial Group Chapter 11 Case – Issues with the FDIC May Be Front and Center

As many parties expected, on March 17, 2023 SVB Financial Group (“SVB Financial” or the “Debtor”) the holding company for Silicon Valley Bank, commenced a case under chapter 11 of the United States Bankruptcy Code (the...more

Cadwalader, Wickersham & Taft LLP

Special Alert: SVB/Signature Receiverships: Key Impacts of SVB/Signature Receiverships on Fund Finance Transactions

It has been a chaotic 72 hours, with changing facts, breaking news and unexpected developments. The market turmoil has kept us scrambling to figure out how best to get deals closed, to keep money moving and to meet our...more

Kilpatrick

Silicon Valley Bank and the Impact of FDIC Bank Receiverships

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On March 10, 2023, the California Department of Financial Protection and Innovation announced that it had closed down Silicon Valley Bank (“SVB”), a financial institution known for its services to start-ups and the venture...more

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