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Risk Management Banks Federal Deposit Insurance Corporation

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

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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

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

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

Venable LLP

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

Venable LLP on

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

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

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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

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

Jones Day

Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

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The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Adams and Reese LLP

FDIC Sends Clear Message in Recent Enforcement Action: BaaS/Fintech Partnerships are a High-Risk Compliance Area

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Last month, the Federal Deposit Insurance Corporation (“FDIC”) took action against a bank for alleged unsafe or unsound banking practices. This, in and of itself, is not usual or newsworthy. What is unusual and newsworthy,...more

Manatt, Phelps & Phillips, LLP

FDIC Proposes Corporate Governance and Risk Management Standards for Select Institutions

In a significant development for state nonmember banks with assets of at least $10 billion (Covered Institutions), the Federal Deposit Insurance Corporation (FDIC) has recently proposed comprehensive corporate governance and...more

Morrison & Foerster LLP

Federal Banking Agencies Adopt Climate-Related Financial Risks Guidance

On October 24, 2023, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (together, the “Agencies”) released their final Principles for Climate-Related...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter -October 2023 # 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

FDIC proposes additions to its safety and soundness standards

On October 5, the FDIC issued a notice of proposed rulemaking that would add a new appendix to the agency’s safety and soundness standards. The new appendix, which would be Appendix C, “is intended to promote strong corporate...more

Cadwalader, Wickersham & Taft LLP

Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools for U.S. Banks

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Cadwalader, Wickersham & Taft LLP

FDIC Issues Bank Failure Post Mortem Report

Recently, the Federal Deposit Insurance Corporation (“FDIC”) issued a report from its Chief Risk Officer entitled FDIC’s Supervision of First Republic Bank. The FDIC was First Republic Bank’s primary federal banking agency,...more

Cadwalader, Wickersham & Taft LLP

FDIC's Annual Risk Review Includes Crypto Risks for First Time

The Federal Deposit Insurance Corporation (“FDIC”) published its annual Risk Review this past Monday, providing an overview of banking conditions for 2022 through early 2023. The FDIC started providing Risk Reviews to the...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

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