Davis Polk Discusses New Permission for Banks to Collect Customer SSNs from Third Parties

In a significant step towards modernizing Bank Secrecy Act compliance, FinCEN and certain banking agencies are providing flexibility in “know your customer” requirements for banks.

The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), …

How to Reinvigorate the FDIC

The Federal Deposit Insurance Corporation (FDIC) is the U.S. agency responsible for insuring all bank deposits and facilitating all bank resolutions. Yet, as only one of three bank regulators, the agency relies on the Federal Reserve (Fed) and Office of …

How to Improve the Bank Charter Application Process

New bank formation in the United States is at an all-time low, and Americans increasingly rely on non-bank financial technology companies (fintechs) to satisfy their financial services needs. Fintechs that do not operate through banks mostly operate outside the direct …

Sullivan & Cromwell Discusses Banking Agencies’ Request for Information About Bank Relationships with Fintechs

On July 25, 2024, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “Agencies”) issued a request for information (the “RFI”)[1] regarding arrangements …

Arnold & Porter Discusses OCC, FDIC Policy Statements on Bank Merger Scrutiny

In recent months, the U.S. banking regulators have proposed policy statements focused on providing greater insight on the agencies’ review of bank mergers and acquisitions under the Bank Merger Act (BMA).[1] On January 29, 2024, the Office of the …