December 23, 2019

To our clients and friends:

On December 12, 2019, the Federal Deposit Insurance Corporation (the “FDIC”) issued a notice of proposed rulemaking (the “Proposed Rule”) to modernize certain aspects of the FDIC’s brokered deposit regulatory framework so that the classification of a brokered deposit appropriately reflects technological changes in the banking industry. The Proposed Rule would create a framework for how the FDIC would analyze certain prongs of the definition of a “deposit broker” under Section 29 of the Federal Deposit Insurance Act and establish an application and reporting process for fintech and other third-party entities to ensure their exemption from being classified as deposit brokers.

Our Alert, which summarizes the key provisions of the Proposed Rule, is available here.

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