The FDIC and OCC propose to codify safety and soundness and reputational risk. This update contains our key takeaways, views on immediate steps banks should consider and a summary of the ...
The OCC has reversed recent changes to its bank merger policies through an interim final rule. Our client update is a refresher on the new state of play for Bank Merger Act applications t...
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...
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...
Davis Polk partner and Financial Institutions practice chair Randy Guynn, counsel Daniel Newman and associate Justin Levine authored “Novel applications may fizzle after Fed master acco...
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...
