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Effective January 10, 2022, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule (the “Primary Purpose Rule”) that adds a specific business relationship that...
On April 1, 2021, the FDIC’s final rule issued in December 2020 revising its brokered deposits regulation became effective. The full compliance date for the final rule is January 1, 2022. The rule established a new framework for analyzing whether deposits made through deposit arrangements qualify as “brokered deposits” and amended the methodology for calculating the interest rate restrictions that apply to less than well capitalized insured depository institutions. The FDIC issued a new Financial Institution Letter ( FIL-23-2021) last week in which it announced that, to facilitate ...
Weekly Fintech Focus FDIC issues an updated brokered deposit rule, creating new exceptions relevant to fintechs working with bank partners. FDIC issues a final rule clarifying its expectations for ILC charter applications. CFPB issues an advisory opinion on Special Purpose Credit Programs to clarify how creditors can offer these programs to disadvantaged groups. CFPB grants access to its compliance assistance sandbox to an earned wage access company, which meets the CFPB’s recent guidance on such programs. PayPal wins the first round in its efforts to throw out aspects of the CFPB’s prepa...
The FDIC has issued a final rule that establishes a new framework for analyzing whether deposits made through deposit arrangements qualify as “brokered deposits” and amends the methodology for calculating the interest rate restrictions that apply to less than well capitalized insured depository institutions (IDIs). The final rule, which includes material differences from the FDIC’s proposal, becomes effective April 1, 2021, with full compliance extended until January 1, 2022. Under the final rule, fewer deposit relationships will be deemed brokered deposits. Brokered Deposits. Se...