Over one year ago, on October 3, 2023, the Federal Deposit Insurance Corporation (FDIC) proposed supervisory guidelines that would establish standards for corporate governance and risk management for all state non-member banks with assets greater than $10 billion (Proposed Guidelines). Unlike guidance, which does not have the force and effect of law, any final guidelines based on the Proposed Guidelines (Final Guidelines) would be issued as Appendix C to the FDIC’s standards for safety and soundness in part 364, pursuant to Section 39 of the FDI Act.
Alexandra Steinberg Barrage
Alex draws on her experience as a former FDIC executive and comprehensive knowledge of bank regulations to advise a wide array of banks and technology companies. She is a sought-after advisor on complex supervisory, regulatory, payments, and transactional issues.
FDIC Extends Comment Period for Proposed Changes to Brokered Deposit Regulations
Today, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all interested parties have sufficient time to review the proposed changes and prepare their comments, the FDIC has extended the comment period from October 22, 2024, to November 21, 2024.
FDIC Publishes Proposed Rule on Recordkeeping for Third-Party Deposits, Opens Comment Period
We previously posted on the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies. Today, the proposed rule was published in the Federal Register and the FDIC is accepting public comments until December 2, 2024.
Where the F(BO) is the Money? Part 2 — Adopting the Right Lessons from Synapse
Guest Contributors: Jonah Crane and Adam Shapiro of Klaros Group
This is the second of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?
In this second article,[i] we focus on encouraging the industry and regulators to adopt the right lessons from Synapse Financial Technologies’ (Synapse) bankruptcy by drawing from the root causes of its failure. We offer some best practices and discuss the potential role of the Federal Deposit Insurance Corporation’s (FDIC) recently proposed recordkeeping rule (Records NPR) — including areas of potential improvement — and conclude by noting how enhanced account ledgering by banks helps address one root cause of the Synapse failure: faulty account ledgering performed only by a third party.
Women in Housing and Finance’s Public Policy Lunch Fireside Chat
Register Here
Monday, September 30 • 12:00 – 1:00 p.m. ET
Troutman Pepper partner Alexandra Steinberg Barrage will moderate the Women in Housing and Finance’s Public Policy Lunch Fireside Chat with FDIC VC Travis Hill on Monday, September 30, 2024 at K&L Gates and virtually via Zoom. They will discuss current topics of interest in…
FDIC Proposes New Rule to Strengthen Recordkeeping for Third-Party Deposits
On September 17, the Federal Deposit Insurance Corporation (FDIC) announced a notice of proposed rulemaking (Proposal) aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies. The FDIC is accepting public comments on the Proposal for 60 days after publication in the Federal Register.
Federal Reserve Bank of San Francisco and DFPI Office of Financial Technology Innovation’s Office Hours
Troutman Pepper Partner Alexandra Steinberg Barrage was a featured speaker at the Federal Reserve Bank of San Francisco and DFPI Office of Financial Technology Innovation’s office hours on September 12. The discussion focused on the impact of financial data on access and financial health.
Where the F(BO) Is the Money? Part 1 – Synapse’s Clarion Call for Standards
This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?
Fintechs and their partner banks are on edge. Regulators are concerned. But as counselors to a wide range of banks and nonbanks, we are confident that the bank-fintech partnership model is not broken. We have seen these partnerships work well — not just for clients, but for consumers and other end-users — with rigorous, risk-based controls that satisfy both the regulators and the public.
FDIC Proposal on Change-in-Control Notices Has Potential Ripple Effects on M&A
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the August 29, 2024 S&P Global Market Intelligence article, “FDIC Proposal on Change-in-Control Notices Has Potential Ripple Effects on M&A.”
Episode 559: Hot Takes: The ERAS Tour of Brokered Deposits
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was a guest on the August 26, 2024 Breaking Banks podcast, “Episode 559: Hot Takes: The ERAS Tour of Brokered Deposits.”