The Federal Deposit Insurance Corporation (FDIC) announced today a 45-Day extension to the public comment period for proposed changes to its regulations that may significantly affect banks, broker-dealers, and FinTechs. The comment due date, which was initially February 13, 2023, is now April 7, 2023.

As discussed in the Client Alert we sent earlier this month, the FDIC’s Notice of Proposed Rulemaking (NPR) would, among other things, require that:

• Banks establish and maintain written policies and procedures to monitor and evaluate the activities of third parties – such as broker-dealers or neobanks – that provide deposit products to their customers; and
• Banks, broker-dealers, or FinTechs revise their customer disclosures regarding arrangements that rely on pass-through deposit insurance, such as brokered CDs, broker-dealer sweep programs, and “neobank” arrangements.

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If you wish to comment, please contact Paul Clark or Casey Jennings. We are happy to provide assistance or answer any questions you might have.