{"asOf":"2026-09-05","merchant":"SSDF INC","kind":"event","id":"fdic-fbo-proposal","date":"2024-10","title":"FDIC custodial-account recordkeeping proposal","kicker":"Watch the NPR","body":"FDIC proposed that banks holding custodial accounts for fintech middleware maintain their own daily reconciled records of beneficial owners rather than relying on the middleware ledger. Subsequent coverage reported the NPR was withdrawn. Treat the operational floor as independent bank-side reconciliation; do not cite a withdrawn NPR as a final rule.","clerk":"FDIC","cites":["FDIC proposed custodial account recordkeeping (fall 2024). Confirm current FR notice before calling it final."],"notes":["This atlas records the proposal and the withdrawal watch. It does not pretend the Code of Federal Regulations already contains a Synapse rule."]}