d in covered custodial deposit accounts such that they would be subject to the Proposal, or if the cash management accounts would be exempt under the Proposal’s exemption for broker-dealers.[] The Proposal contains no minimum threshold for numbers or volume of custodial deposit accounts with transactional features or the asset size of the banks, thereby applying to any and all banks holding such accounts.[] SeeStatements of Chairman Martin Gruenberg, Vice Chairman Travis Hill, Jonathan McKernan, Rohit Chopra, and Michael J. Hsu dated September 17, 2024.[] In connection with the Joint Statement on Banks’ Arrangements with Third Parties to Deliver Bank Deposit Products and Servicesin July, the agencies also published a request for information seeking comment on bank-fintech arrangements, including associated risk management practices and implications. See Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses, 89 Fed. Reg. 61577 (July 31, 2024). The comment period for the request for information ends October 30, 2024.[View source.]