Recent actions underscore key concerns from regulators over the Banking-as-a-Service (BaaS) model and signal that additional guidance may be forthcoming.
Recent Supreme Court decisions show a strong and continued rebalancing of power in the administrative state that has been years in the making. This update outlines what it means for the f...
FDIC has revamped its IDI Rule resulting in major changes in the resolution submissions for covered banks. Our visual memo, linked below, summarizes key components of the final rule and p...
In a unanimous decision, the Supreme Court held the NRA plausibly alleged that former DFS Commissioner Maria Vullo coerced DFS-regulated entities into cutting ties with the NRA based sole...
Davis Polk Financial Institutions practice chair Randy Guynn, counsel Ledina Gocaj and associate Andrew Tynes authored “Exec liability bill for failed banks is unnecessary, unwise” in...
Davis Polk partner and Financial Institutions practice chair Randy Guynn, counsel Daniel Newman and associate Justin Levine authored “Novel applications may fizzle after Fed master acco...
The courts rejected arguments that the Federal Reserve Banks are required to grant master accounts to all legally eligible depository institutions. We analyze the rulings and their broade...
This update analyzes comments that the FDIC received from a wide range of stakeholders on its corporate governance proposal. Not surprisingly, commenters are overwhelmingly opposed.
