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Financial Services Law Insights and Observations

FDIC rescinds disclosure requirements for insured state nonmember banks

Agency Rule-Making & Guidance FDIC Disclosures Of Interest to Non-US Persons

Agency Rule-Making & Guidance

On March 18, the FDIC published a final rule to rescind and remove 12 CFR Part 350, Disclosure of Financial and Other Information By FDIC-Insured State Nonmember Banks. Effective April 17, all insured state nonmember banks and insured state-licensed branches of foreign banks will no longer be subject to the annual disclosure statement requirement set out in the existing regulations. The FDIC’s rescission and removal is an attempt by the FDIC to simplify its regulations and “remov[e] unnecessary or redundant regulations.” The FDIC concluded that Part 350 is “outdated and no longer necessary” because information technology advancements now provide the public with direct access to information on the condition and performance of individual banks.