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On Nov. 18, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a 45-day extension to the public comment period for its proposed rule making (Proposed Rule) that would establish new recordkeeping requirements and related compliance obligations for insured depository institutions that offer certain “custodial deposit accounts with transactional features.”

As we detailed in a prior…

On Oct. 25, 2023, the Fed proposed a rule to lower the interchange fee cap in Regulation II, which is largely applicable to debit card issuers with at least $10 billion in consolidated assets. The proposed rule would be the first time that the debit interchange cap has been adjusted since its implementation via the…