Yesterday the FDIC issued a Notice of Proposed Rulemaking that would modify the deposit insurance assessment system for small banks (those with less than $10 billion in assets). The new proposal is a modification from a June 2015 rulemaking notice. The new proposal would revise the one-year asset growth measure, use a brokered deposit ratio instead of a core deposit ratio for established small banks, remove the exiting brokered deposit adjustment that applies to banks outside Risk Category I, and revise the weights assigned to the proposed measures in the financial ratios method. Although these are not drastic changes, they slightly relax some of the regulatory requirements imposed on community banks.
This blog is intended to provide timely updates and commentary on recent developments in legal and regulatory issues affecting community banks. The topics covered will include civil litigation involving banks, regulatory updates, enforcement actions brought by bank regulators (including the OCC, FDIC, Federal Reserve, and CFPB), and data security issues that affect banks.
I am a commercial trial attorney at Reese Gordon Marketos in Dallas. I have represented clients across a number of industries, but my family ties to the banking industry led me to focus a significant portion of my practice on the representation of community banks. My father has been a community banker for more than 30 years, and my grandfather is a banking professor and former community banker. As a result, I grew up around the banking industry and developed a special appreciation of the business needs of banks and the problems that litigation and regulatory enforcement actions can create for banks. It is my hope that this blog will provide helpful content to community bankers and assist them in avoiding or solving problems created by litigation and regulatory issues.