After reviewing the proposal’s statutory basis, coverage, and operative requirements, Mr. Court explains the basis for BPI’s position that the proposal is inconsistent with how banking is regularly conducted and will undermine rather than promote safety and soundness, provides examples of how the proposal would impose unworkable requirements, and discusses BPI’s Freedom of Information Act

FDIC Chairman Jelena McWilliams recently stated that the FDIC is not contemplating a rulemaking “at this time” similar to the OCC’s proposed fair access rule issued last month.

Chairman McWilliams made this statement in response to a question asked during the FDIC’s presentation of third quarter 2020 results for FDIC-insured institutions. Ms. McWilliams was