Troutman Pepper Partners Alexandra Barrage and Matthew Bornfreund were quoted in the August 5, 2024 S&P Global article, “FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core.”
Turning Back the Clock: FDIC Proposes Significant Changes to 2020 Brokered Deposit Rule
On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s definition of “deposit broker,” related exceptions, and Q&As. Many of the proposed changes effectively reverse the 2020 Rule.
Did Regulators Send Warning Shot at Already Roiled BaaS Space?
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 31, 2024 Banking Dive article, “Did Regulators Send Warning Shot at Already Roiled BaaS Space?“
Pledging ‘Accountability,’ Biden’s FDIC Pick Faces Senate Test
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 10, 2024 Law360 article, “Pledging ‘Accountability,’ Biden’s FDIC Pick Faces Senate Test.”
“She’s going to get lots of questions about her banking experience, her bank regulatory experience and her leadership and management experience,” said Alexandra Steinberg Barrage, a
What Is the Cost of Doing Banking as a Service ‘Well’?
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 26, 2024 American Banker article, “What Is the Cost of Doing Banking as a Service ‘Well’?”
“In my experience, there is always some tweaking,” said Alexandra Barrage, a partner at Troutman Pepper.
Leaders across the bank – from
Hsu Signals OCC to Review Preemption Rules
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 18, 2024 Banking Dive article, “Hsu Signals OCC to Review Preemption Rules.”
Hsu’s comments suggest the OCC’s preemption rules following Dodd-Frank can’t really be relied on anymore, said Alexandra Steinberg Barrage, a partner at law firm Troutman Pepper
Loper Bright and Cantero Are Ushering in a New Era of Preemption
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 18, 2024 American Banker article, “Loper Bright and Cantero Are Ushering in a New Era of Preemption.”
“If I’m a national bank, I’m going to rethink my reliance on those preemption rules, given what the Supreme Court has
Ex-FDIC Executive Targets Bridging Legal and Business at Troutman
Alexandra Steinberg Barrage, a partner with Troutman Pepper, was quoted in the June 18, 2024 IFLR article, “Ex-FDIC Executive Targets Bridging Legal and Business at Troutman.”
Speaking to IFLR about her move, she said: “I was attracted to Troutman because of its existing platform of bank and non-bank clients. The firm is committed
FDIC Finalizes Amendments to Regulations Governing Official Signs, Advertising Requirements, and Misrepresentations Regarding Deposit Insurance Coverage
The Federal Deposit Insurance Corporation (FDIC) has recently issued a final rule amending its regulations governing the use of official FDIC signs and insured depository institutions’ (IDIs) advertising statements. The new rule took effect on April 1, 2024, with an extended compliance date of January 1, 2025. The extended compliance date is intended to provide sufficient time for financial institutions to put in place processes, systems, and technological updates to implement the new regulatory requirements.
Federal Banking Agencies Issue New Guidebook for Community Banks Managing Third-Party Relationships
On May 3, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the agencies) released a guidebook aimed at assisting community banks in managing risks associated with third-party relationships (the TPRM Guide). The TPRM Guide builds upon the principles introduced in the third-party risk management guidance for banking organizations issued by the agencies in June 2023 (the June 2023 Guidance, discussed here) as well as the agencies’ community bank guide for conducting due diligence on fintech companies from October 2023 (discussed here) but does not displace or substitute that prior guidance.