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...
This update analyzes comments that the FDIC received from a wide range of stakeholders on its corporate governance proposal. Not surprisingly, commenters are overwhelmingly opposed.
The OCC’s proposed changes to its approach to Bank Merger Act applications are a missed opportunity to provide certainty around bank mergers in an uncertain market.
