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The Silicon Valley Bank (“SVB”) closure was the largest bank failure since the 2008 financial crisis—and second largest in U.S. history.  While the banking industry, federal banking agencies and the market at-large continue to react to the fallout and look to determine the root causes, the industry is likely to see a number of potential changes in the shadow of this recent crisis.  Below are some thoughts on the potential consequences of the SVB failure.   Continue Reading 2023 Banking Crisis:  What Next?

The U.S. Department of the Treasury (the “Treasury”), the Board of Governors of the Federal Reserve System (the “FRB”) and the Federal Deposit Insurance Corporation (the “FDIC” and collectively with the Treasury and the FRB, the “Agencies”) took several actions on March 12, 2023 in an effort to contain the fallout from the recent failure of two insured depository institutions. Those actions are noted below.Continue Reading U.S. Government Agencies Address Recent Bank Failures and Fallout

On March 23, 2021, the Illinois Community Reinvestment Act (“IL CRA”) was signed into law.  The stated purpose of the IL CRA is to ensure that covered financial institutions are equitably providing financial services across the state, including to low- and moderate-income neighborhoods, and areas where there is a lack of access to safe and affordable banking and lending services.  Since that time, the Illinois Department of Financial and Professional Regulation (the “IDFPR”) has been working to finalize the IL CRA’s implementing regulations. Continue Reading Watching-and-Waiting: The Illinois Community Reinvestment Act

On October 18, 2022, the FDIC finalized a rule to increase initial base deposit insurance assessment rate schedules uniformly by 2 basis points, beginning in the first quarterly assessment period of 2023.  The stated purpose of the increase in assessment rate schedules is to “increase the likelihood that the reserve ratio of the Deposit Insurance

On March 30, 2022, the Federal Deposit Insurance Corporation (the “FDIC”) issued a notice regarding a proposed Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (the “Principles”).  The notice also requests comments from the public on the proposed Principles.  The Principles are substantively similar to those issued by the Office of the Comptroller of the Currency on December 16, 2021.  As proposed, the Principles would create a high-level framework for the safe and sound management of exposures to climate-related financial risks.Continue Reading UPDATE: FDIC Issues Proposed Statement of Principles for Managing Exposure to Climate-Related Financial Risks