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The DOJ, FDIC and OCC have revised their bank merger review standards. The new standards are a major shift for bank M&A and will require a careful, detailed analysis to evaluate the viabi...
The FDIC’s proposed amendment to its CIBCA regulations would give the FDIC greater oversight of investments by non-bank investors in holding companies of FDIC-supervised institutions. ...
The FDIC’s proposed brokered deposit rule would expand the definition of deposit broker and eliminate and narrow exceptions. Changes would affect sweep deposit and fintech arrangements.
The FDIC recently finalized two items of guidance for triennial full filer Title I resolution plans (originally proposed last year) and announced the extension of the 2025 resolution plan...
Recent actions underscore key concerns from regulators over the Banking-as-a-Service (BaaS) model and signal that additional guidance may be forthcoming.
FDIC has revamped its IDI Rule resulting in major changes in the resolution submissions for covered banks. Our visual memo, linked below, summarizes key components of the final rule and p...
In a unanimous decision, the Supreme Court held the NRA plausibly alleged that former DFS Commissioner Maria Vullo coerced DFS-regulated entities into cutting ties with the NRA based sole...
The Officer of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Federal Housing Finance Agency (FHFA) have re-proposed the same rule from 20...
The courts rejected arguments that the Federal Reserve Banks are required to grant master accounts to all legally eligible depository institutions. We analyze the rulings and their broade...