The FDIC's plans to facilitate bids on failed banks by nonbank firms is particularly noteworthy. Now is the time for such firms to be engaging in the pre-qualification process if they want to bid on failed bank assets.

In its letter, the IIB notes that it has been commenting on these issues for over a decade and that the FFIEC 009 reporting form is not just an administrative information collection, but instead has a significant potential impact on regulatory outcomes. It will be interesting to see if IIB's comments gain traction in the new regulatory environment.

The ABA’s letter sets out a number of areas where states are seeking to apply state banking law to national banks, thereby interfering with the operations of national banks, especially those that operate on a multistate basis. Some issues are longstanding ones and some reflect more recent initiatives, such as state regulation of AI. 

States have become more assertive in recent years on a number of bank regulatory fronts, including to support industries in their states and to fill…

The Vice Chair's remarks highlight priorities for the FDIC in the new presidential administration. To a great extent, these priorities are a continuation of those advocated by the FDIC Chair under the first Trump administration. The FDIC board can be expected to back these initiatives because two members of the FDIC board are the Comptroller of the Currency and the Chair of the CFPB, both of which are presidential appointees, and these can be expected to change with the new administration.…