Troutman Pepper was recently engaged by the Financial Technology Association (FTA) to draft its response to the Federal Deposit Insurance Corporation’s (FDIC) Request for Comment on its Brokered Deposit Notice of Proposed Rulemaking.

An excerpt from the FTA’s Comment Letter was highlighted in a November 21, 2024 article by Law 360.

“The proposal is based on conjecture and, read most generously, experience that the FDIC has presumably gained behind the scenes,” the FTA said in a Thursday letter, but “the lack of any quantitative data undermines the integrity of the APA-mandated rulemaking process.”

You can read more about comment letters that were filed to the FDIC in this article.