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ARTICLE · 14 OCTOBER 2024

FDIC Proposes New Requirements For Custodial Accounts

Greenberg Traurig
Greenberg Traurig
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On Oct. 2, 2024, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking (Proposed Rule) designed to strengthen recordkeeping requirements for custodial deposit accounts with transactional feature.

United StatesFinance and Banking
Go-To Guide:
  • The FDIC issued a notice of proposed rulemaking (Proposed Rule) that would impose new recordkeeping requirements for certain custodial deposit accounts, like those often used in bank-fintech partnerships.
  • The Proposed Rule is intended to ensure the FDIC's ability to promptly make deposit insurance determinations; however, costs to comply with the new requirements could be significant.
  • FDIC-insured banks and fintechs should review their business models and assess what steps they may need to take to comply.
  • Those impacted by the Proposed Rule, if adopted in its current form, should also consider submitting comments by Dec. 2, 2024, to voice their concerns with the proposed requirements.

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