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Non-Bank Lenders Federal Deposit Insurance Corporation FinTech

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

Perkins Coie on

The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Husch Blackwell LLP

FDIC Publishes FAQs on the New FDIC Signage, Advertisement, and Deposit Insurance Misrepresentations Rule

Husch Blackwell LLP on

Last week, the Federal Deposit Insurance Corporation (FDIC) published Frequently Asked Questions on the final rule governing FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured...more

Goodwin

FDIC Approves ILC With Traditional Bank Business Model (But Don’t Rush To Submit Your Application Just Yet)

Goodwin on

An industrial bank or industrial loan company (each, an ILC) charter can be an attractive option for a financial technology company (fintech) or other company seeking to enter the banking space. In June 2024, the Federal...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

Seward & Kissel LLP

Proposed FDIC Rule Would Impose Additional Deposit Insurance Disclosure Obligations on Banks and Non-Banks

Seward & Kissel LLP on

The Federal Deposit Insurance Corporation (“FDIC”) published for comment in December 2022 a notice of proposed rulemaking (12 CFR Part 328) (“Proposed Rule”) that would apply to all FDIC-insured institutions and impose new...more

Bradley Arant Boult Cummings LLP

OCC Releases Final True Lender Rule

On October 27, 2020, the OCC released its final True Lender Rule. As discussed earlier on this blog, the OCC’s rule is designed to clarify the “true lender” doctrine, a legal test utilized by courts and regulators to...more

Troutman Pepper

OCC Bulletin For Third-Party Oversight Breaks New Ground For Bank Relationships With Fintechs

Troutman Pepper on

New third-party oversight guidance issued by the OCC should spur increased financial innovation at national banks. On March 5, the OCC issued OCC Bulletin 2020-10, Frequently Asked Questions to Supplement OCC Bulletin...more

Nutter McClennen & Fish LLP

Fintech in Brief: FDIC Signals Pending Decisions on ILC Applications and Proposes New Rules for ILCs and their Parent Companies

On March 17, the FDIC released for public comment a proposed rule for industrial banks and industrial loan companies (together, “ILCs”) and their parent companies and signaled that it is considering two pending ILC...more

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