On November 1, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) issued modifications to its Statement of Policy (“SOP”) for applications made under Section 19 of the Federal Deposit Insurance Act (“FDIA”). The modifications are expected to reduce the number of Section 19 applications FDIC-supervised institutions must submit prior to submitting offers of employment.
Background
On January 8, 2018, the FDIC published in the Federal Register notice of proposed modifications and sought public comment. On July 19, 2018, after consideration of comments received, the FDIC approved modifications to the SOP’s exceptions to filing an application and made additional technical and clarifying changes.Continue Reading Update: When Are Section 19 Application Required?