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
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On May 1, 2023, the Federal Deposit Insurance Corporation (the “FDIC”) released a comprehensive discussion and analysis of potential courses of action that could be taken to reform the deposit insurance system in response to the recent string of failures of insured depository institutions.  The three options for reform are briefly described below:

Continue Reading FDIC Proposes Potential Reforms to Deposit Insurance in the U.S. Banking System

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?
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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
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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