Bank Bryan Cave

Recent Posts from Bank Bryan Cave

• Updated Guidance on Seeking a “High-Rate Area” Determination

  The FDIC has not yet formally published the anticipated guidance on how an institution can seek a “high-rate area” determination under the national interest rate restrictions for less than well-capitalized banks.  However, based on conversations…

• Updated Guidance on Prepaid Assessment Exemptions

  Standards for Prepaid Assessment Exemptions We understand that the FDIC has decided to exempt the following categories of financial institutions from the requirement to prepay three years of deposit assessments: Institutions with a CAMELS rating…

• FDIC Finalizes Prepaid Assessments Rule

  On November 12, 2009, the FDIC adopted its final rule regarding prepaid assessments.  The final rule is largely unchanged from the FDIC’s initial proposal; the most significant change is that the FDIC will now refund…

• News Roundup — November 5, 2009 to November 13, 2009

  Payments PayPal officialy launched its new platform entitled “PayPal X” for third party developers on November 5, 2009, making it easier to integrate the payment system with other Web sites and applications. Continuing fallout from…

• October TARP Capital Infusions – TARP Map and List of Recipients Updated

  During the month of October, the Treasury completed rounds forty-six, forty-seven, and forty-eight of TARP Capital infusions.  In these three rounds, which closed on October 2,  October 23, and October 30, respectively, the Treasury purchased a total…

• FDIC Issues New Guidance Relating to the Brokered Deposit/Interest Rate Restrictions

  As we have discussed earlier, the FDIC has revised the brokered deposit/interest rate restrictions to create a presumption in favor of a “national deposit rate” starting January 1, 2010. Under this new rule, financial institutions…

• Red Flags Rule Compliance is Delayed to June 10, 2010 in a Last Minute Decision

  The FTC announced over the weekend that, at the request of members of Congress, the compliance date for the Red Flags Rule is now delayed to June 1, 2010. This gives companies additional time to prepare…

• Policy Statement on Prudent Commercial Real Estate Loan Workouts

  Regulators and financial institutions have been trying for some time now to come to an understanding of what type of how workout strategies affect the classification of loans and the corresponding impact on estimates of…

• News Roundup — October 26, 2009 to October 30, 2009

  Gift Cards The Consumer Federation of America issued a press release on October 27, 2009 in relation to a survey that demonstrates the depth of consumer misunderstanding when it comes to gift cards. According to…

• October 2009 Client Alerts

  FinCEN’s New Bank Secrecy Act Compliance Outreach Initiative Targeted at Depository Institutions With Assets Under $5 Billion Yesterday FinCEN announced a new outreach initiative targeted at depository institutions with assets under $5 billion. The outreach…