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Matthew provides comprehensive guidance to clients on a wide range of regulatory, transactional, and compliance matters, helping them to advance their operational goals and launch new products and services. His clients include domestic and international traditional and nontraditional banks, as well as fintechs, private equity funds, and payment services firms.

On January 20, Travis Hill became the Acting Chairman of the Federal Deposit Insurance Corporation (FDIC). Following his remarks on FDIC policy issues on January 10 at the American Bankers Association, in his first statement as Acting Chairman, Hill highlighted various priorities and mentioned new initiatives, emphasizing a commitment to regulatory reform, innovation, and a focus on core financial risks.

On January 10, the Consumer Financial Protection Bureau (Bureau) issued a notice of proposed interpretive rule (Proposed Rule). The deadline for comments is March 31, 2025. The Proposed Rule would apply the Electronic Fund Transfer Act (EFTA)—which protects consumers against errors and fraud—to new types of digital payment mechanisms, including stablecoins and other digital currencies.

On January 8, the United States District Court for the Southern District of New York dismissed the claims brought by Banco San Juan Internacional, Inc. (BSJI) against the Federal Reserve Bank of New York (FRBNY) and the Board of Governors of the Federal Reserve System (Board). BSJI alleged that the termination of its master account by the FRBNY violated various federal laws. The ruling in the BSJI case underscores the discretionary authority of Federal Reserve Banks in granting or denying master accounts.

In a previous post, we discussed 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. The proposed rule initially set a public comment period ending on December 2, 2024. Yesterday, the FDIC announced a 45-day extension to this comment period, now allowing stakeholders until January 16, 2025, to submit their feedback.

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.

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.

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.

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.

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.