On January 19, 2021, the FDIC’s Board of Directors approved revised Guidelines for Appeals of Material Supervisory Determinations (the “Guidelines”), which are applicable to insured depository institutions (“IDIs”) the FDIC supervises as well as other IDIs for which the FDIC makes material supervisory determinations. The FDIC stated that the amendments are intended to: (1) improve the independence of appeals decisions via the implementation of an independent, standalone office—the Office of Supervisory Appeals (the “Office”)—that will replace the existing Supervision Appeals Review Committee (the “SARC”); and (2) clarify the procedures and timeframes applicable to appeals, including those relating to formal enforcement actions.
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On October 5, 2016, the CFPB issued its long-awaited final prepaid accounts rule. The rule applies to traditional prepaid cards, such as general-purpose reloadable cards, as well as a variety of other products, including mobile wallets, person-to-person payment products, payroll cards, student financial aid disbursement cards, tax refund cards, and certain government benefits cards, such as cards for unemployment and child support disbursements.  Providers of these products generally must comply with the rule by October 1, 2017.  The key aspects of the rule include required consumer protections, product disclosures, and requirements applicable to products with credit or overdraft features.
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