The Return of the ILC: The FDIC Issues Its Final Rule
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- On December 15, 2020, the Federal Deposit Insurance Corporation (the “FDIC”) finalized its regulatory framework to strengthen and codify the FDIC process for approving federal deposit insurance applications for industrial banks and for supervising industrial bank holding companies (the “Final Rule”).
- The Final Rule largely adopts the framework in the March 17, 2020 proposal, but with a few key differences, including a new reporting obligation that requires covered companies to inform the FDIC about their systems for protecting the security, confidentiality and integrity of consumer and nonpublic personal information.
- The Final Rule becomes effective on April 1, 2021.