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by Michele Alt, Roman Goldstein, and Patrick Haggerty To protect stablecoin holders from issuer insolvency, GENIUS: Requires an issuer to hold full and segregated reserves against all its outstanding stablecoins; Provides holders of stablecoins issued by a nonbank issue r a superpriority claim in bankruptcy on those reserves and the issuer’s other assets; and Prescribes a non-bankruptcy resolution process for any insolvent bank issuer . Congress, however, overlooked a few imp

The rapid emergence of artificial intelligence (AI) technologies creates a new pool of cyber risk, and a material commercial reason for partner banks to focus on information security.

On October 9, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) and the primary federal banking agencies issued “FAQs Regarding Suspicious Activity Reporting Requirements” to clarify four specific provisions that many financial institutions have incorporated into their Bank Security Act and anti-money-laundering (BSA/AML) programs to reduce the burdens related to SAR filings. We’ve summarized the FAQs below to help financial institutions un

In addition to Industrial Loan Companies (ILCs), Merchant Acquirer Limited Purpose Bank Charters (M-A-L-P-Bs), and Special Purpose Depository Institutions (SPDIs), National Trust Banks (NTBs), CEBA banks, and Payments National Banks (PNBs) have emerged as contenders.

Banks and bank holding companies issued $45 billion of subordinated debt in the short period from late 2020 through 2022 and a wave of sub debt refinancings is just beginning to reach the market. Are we ready?

Differences between bank and bank holding company (BHC) capital requirements provide BHCs greater flexibility to optimize their capital structure, creating incentives for the issuance of subordinated debt (sub debt). Sub debt issuance spiked from late 2020 through 2022 as companies sought to take advantage of pandemic-era near-zero interest rates and a flood of investors seeking meaningful yield.

Discover how AI is shifting banks from reactive RegTech to proactive RiskTech spotting structural risks, not just ticking compliance boxes.

What kind of bank charter is best? As Peter Renton and I discussed recently on the Fintech One on One podcast , the attitude in Washington has changed dramatically with the new administration, and there’s renewed interest in and optimism around bank charters. Here’s a quick run-down on what the options are.  Build (De Novo) vs. Buy (Acquisition) : The important thing is that at this point there’s no difference in approvability: the regulators will look just as hard at an acqu

What happens to a fintech’s valuation if it becomes a bank? Periodically, Klaros nonbank clients ponder the potential impact on their enterprise valuation if they were to seek a bank charter. Klaros is an advisory and investment firm, so we leave valuation questions to our friends within the investment banking profession, but the following general parameters may be helpful for fintechs and others considering pursuit of a bank charter. 1. Business Model is Key Driver of Valu

Bank M&A, which hit a five-year low  in 2023, may finally be poised for a comeback. Atlantic Union Bancshares Corporation (NYSE: AUB) has...

Konrad Alt and Patrick Haggerty The Synapse bankruptcy is raising fresh concerns about the challenges of protecting depositors whose funds are held in FBO accounts when a critical partner fails. In this case, Synapse’s collapse is exposing issues that can surface when a fintech platform suddenly folds. But one need only think back to last year to remember that FBO accounts also present unique depositor protection challenges when a fintech’s bank partner fails.  In this post w

BY BRIAN GRAHAM The recent rescue of NYCB through the infusion of private capital comes almost exactly a year after the collapse of Silicon Valley Bank. In the intervening 12 months, sentiment has seemingly gyrated between “the sky is falling” (i.e. a lot of banks will fail) and “nothing to see here” (i.e. banks are fine). As is usually the case, the truth lies in the middle: the banking industry faces severe stress but, at least so far, it looks like few banks are insolvent

BY KEVIN STEIN AND BRIAN GRAHAM Industry results for the fourth quarter of 2023 were weak on average; the largest banks outperformed and the regional banks materially underperformed. This was in line with expectations, capping a very challenging year for the banking industry. Increased FDIC assessments for the Spring 2023 failures, one-time charges for staffing reductions, and idiosyncratic credit charges contributed to the weak results. But overall the fourth quarter earning

It’s been 1,166 days since the OCC’s last fintech de novo approval but if you want to charter a new bank or acquire or merge with an existing bank, don’t give up.

Banks are under intense pressure as nearly $1 trillion in unrealized losses loom, will rate cuts save them or simply delay the reckoning?

BY MICHELE ALT For years, scenes from “It’s a Wonderful Life” played on a loop in the FDIC’s public foyer, illustrating the romantic lens...

BY SIMON GILBERT In our meetings with clients, the three most common words are “a”, “the”, and “capital.” And it’s not surprising: some...

As the banking crisis continues to unfold, regulators who scrutinize banks, fintechs wondering if their banking partner is sound, and...

The Fed’s announcement regarding its Novel Activities Supervision Program makes clear that some state member banks that partner with...

BY KEVIN STEIN FDIC Chairman Marty Gruenberg’s recent speech at the Brookings Institution Center for Regulation and Markets had some...