The Federal Deposit Insurance Corporation (FDIC) recently proposed and published a Federal Register notice for a proposed rule that would revise the agency’s Change in Bank Control Act (CIBCA) regulations. Specifically, the proposed rule would add a second layer …

On July 25, 2024, the U.S. prudential bank regulators released a Joint Statement on Banks’ Arrangements With Third Parties To Deliver Bank Deposit Products and Services (Joint Statement),¹ along with a request for information on bank-fintech arrangements (RFI) issued …

On July 30, 2024, on a party line 3-2 vote of its Board of Directors, the Federal Deposit Insurance Corporation (the “FDIC”) approved a Notice of Proposed Rulemaking^[1] (the “Proposal” or the “Proposed Rule”) to substantially broaden the scope …

In a recent opinion piece in the Washington Post, former FDIC Chair Sheila Bair and leading British bank historian Charles Goodhart argued in favor of the executive compensation clawback provision in the proposed RECOUP Act, which we analyzed …

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 …

The Federal Deposit Insurance Corporation (FDIC) released a Proposed Statement of Policy on Bank Merger Transactions (the Proposal) that outlines the FDIC’s views on its jurisdiction and expectations with respect to each statutory factor under the Bank Merger Act (BMA).…

In October 2023, the FDIC proposed enforceable guidelines on corporate governance and risk management that would apply to all state non-member banks with $10 billion or more in assets.

Key Facts:

• The comment period closed on February 9, 2024
• 66

The FDIC’s final special assessment is largely unchanged from the proposed rule:

• The assessment base is equal to the amount of an insured depository institution’s (IDI) uninsured deposits, as reported for the quarter ended December 31, 2022, minus up to

On October 11, 2023, the Federal Deposit Insurance Corporation (the “FDIC”) published in the Federal Register for comment a notice of proposed rulemaking to establish new guidelines (the “Proposed Guidelines”) for governance and risk management at FDIC-supervised insured depository institutions …

On August 29, 2023, US federal banking regulators issued a proposal for long-term debt (“LTD”) requirements for certain midsize and larger US banking organizations (the “LTD Proposal”).¹ The LTD Proposal is important because it would require many regional and …

On July 27, the three federal banking agencies (the Agencies)[1] jointly proposed changes to the regulatory capital framework applicable to large banks and bank holding companies (the Proposal). The Proposal is the U.S. adaptation of the 2017 revisions to …

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and (ii) change the method for calculating the capital surcharge …