United States:
FDIC Provides Guidance For Non-Traditional Banks On Deposit Insurance Applications
18 February 2020
Cadwalader, Wickersham & Taft LLP
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The FDIC provided guidance for non-traditional
community banks on deposit insurance applications. The agency also
updated its Handbook for Organizers of De Novo
Institutions ("Handbook") and its Deposit Insurance Application Procedures
Manual ("Procedures Manual").
In a Supplement to the Procedures Manual, the FDIC
provided guidance on submitting deposit insurance applications. The
Supplement addresses topics such as (i) field investigations, (ii)
approval conditions and (iii) application review processes.
The FDIC also updated its Handbook to (i) provide more
information on pre-filing activities, the application process and
pre-opening efforts involving deposit insurance applications, (ii)
include several technical clarifications and (iii) to explain
certain conditions requiring prior approval of business plan
changes.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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