Liquidity

The FDIC's ILC RFI is missing a very important section on funding. Deposit and funding strategy issues determine the outcome of many ILC applications. Here are some questions they could have asked: How should the FDIC assess an applicant business plan funded primarily by sources other than customer deposits? Should the FDIC's analysis differ to the extent the proposed funding consists of: (1) traditional brokered deposits, (2) securitization, (3) secured wholesale borrowings, (4) parent credit lines or asset purchases? In the case of securitization, how much weight should the FDIC give the...

We advise banks, fintechs, mortgage companies and others on regulatory compliance across the full spectrum of consumer protection and prudential requirements. Our regulatory practice covers consumer compliance (TILA, RESPA, UDAP/UDAAP, FCRA, HMDA, fair lending), safety and soundness issues, payments rules, and regulatory change management. We help clients understand the impact of new regulations, build compliance programs, and maintain comprehensive regulatory inventories. Services provided by the Regulation & Compliance practice include: Capital Analysis: We assess treatment of assets,...

BJ Sanford advises payments and fintech companies, U.S. and foreign banks, trade associations, investors, and policy and consulting firms. His practice centers on payments regulation, public policy, and the regulation of bank activities and structure. He also advises clients on regulatory capital, bank investments and control, affiliate transactions, the U.S. operations of foreign banks, and regulatory examinations. Payments regulation. BJ advises payments firms and banks on payment regulation, product development, and compliance with rules including Regulation E, Regulation Z, Regulation II...