De Novo Bank Formation

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On June 6, 2023, in an effort to promote consistency and clarity across the bank regulatory landscape, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency (together, the “Agencies”) issued joint guidance offering the Agencies’ combined approach to bolstering regulated banking organizations’ risk management practices with respect to third-party relationships (the “Guidance”). While the Guidance replaces each of the respective Agencies’ preexisting materials on this subject, many of the concepts advocated for and advanced by former guidance documents and/or FAQs have been incorporated into the final form of the Guidance.Continue Reading Federal Reserve, FDIC and OCC Issue Streamlined Guidance to Mitigate Risks Associated with Third-Party Relationships

Watching and waiting2

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

Please join James M. Kane and James W. Morrissey, Co-Chairs of the Financial Institutions Group, and Mark C. Svalina, Associate, at Vedder Price, for a webinar presentation on regulatory, compliance and related issues banks can expect to encounter in 2022.
Continue Reading Banking Update Webinar- What to Expect in 2022

Please join James W. Morrissey, Co-Chair of the Financial Institutions Group, and Mark C. Svalina, Associate, at Vedder Price, for a webinar presentation on regulatory, compliance and related issues banks can expect to encounter in 2022.
Continue Reading Banking Update Webinar- What to Expect in 2022

On July 11, 2018, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Board of Governors of the Federal Reserve System (“FRB”) (the OCC, FRB and FDIC are collectively, the “Federal Banking Agencies”) issued revisions to the Interagency Biographical and Financial Report (the “Report”).

In general, individual directors, officers, or an individual or group of shareholders acting in concert that will own or control 10 percent (10%) or more of a bank must file the Report in connection with the following: (i) applications to establish a de novo bank, (ii) notices for a change in control, (iii) Section 914 applications for new executive officers and directors, and (iv) applications for new executive officers and directors following a change in control.Continue Reading Bringing a Level of Clarity to the Interagency Biographical and Financial Report