On Jan. 28, 2015, the Federal Deposit Insurance Corporation (FDIC) in a Financial Institutions Letter (FIL) announced that it would, in effect, do an about-face on its supervisory expectation that banks strongly consider discontinuing the provision of financial services to entire categories of certain purportedly high-risk customers. These categories of customers included, to name a few, non-U.S. companies, online gambling-related operations, online lenders, pharmaceutical sales, telemarketing entities, coin dealers, firearm and ammunition sellers, and even dating services. In this post, the authors discuss the FDIC’s position change and how financial institutions may be affected.

Continue Reading.