The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has long recognized non-financed (i.e., “all-cash”) transfers of residential real estate as susceptible of money laundering because these methods
Continue Reading FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting RequirementsCompliance
CFPB Broadens Supervisory Appeals Process
On Feb. 16, 2024, the Consumer Financial Protection Bureau (CFPB) updated its internal supervisory appeals process for institutions seeking to appeal a compliance rating or an adverse material finding. This…
Continue Reading CFPB Broadens Supervisory Appeals ProcessHawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency Activities
On Jan. 25, 2024, the Hawaii Department of Commerce and Consumer Affairs Division of Financial Institutions (DFI) and the Hawaii Technology Development Corporation (collectively, the “Agencies”) jointly issued a press…
Continue Reading Hawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency Activities5 Trends to Watch: 2024 UK Financial Services Regulation
This 5 Trends piece covers non-financial misconduct, the Senior Managers and Certification Regime, FCA investigations and Upper Tribunal proceedings, motor finance, and FCA Sustainability Disclosure Requirements. …
Continue Reading 5 Trends to Watch: 2024 UK Financial Services Regulation
FDIC Issues Cease and Desist Letters to 5 Entities for Making False or Misleading Representations Regarding Deposit Insurance
On Jan. 19, 2024, the Federal Deposit Insurance Corporation (FDIC) issued letters demanding five entities and certain associated parties cease and desist from making false and misleading statements about FDIC…
Continue Reading FDIC Issues Cease and Desist Letters to 5 Entities for Making False or Misleading Representations Regarding Deposit InsuranceCFPB Proposes Rule to Reclassify Overdraft Fees Under TILA
In a move that could reshape the landscape of consumer finance, on Jan. 17, 2024, the Consumer Financial Protection Bureau (CFPB) proposed a new rule that aims to redefine overdraft…
Continue Reading CFPB Proposes Rule to Reclassify Overdraft Fees Under TILAFinCEN Publishes Final Rule on Access to Beneficial Ownership Information
On Dec. 22, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule (Access Rule) establishing the parameters for authorized access to BOI reported…
Continue Reading FinCEN Publishes Final Rule on Access to Beneficial Ownership InformationCorporate Transparency Act Takes Effect with Beneficial Ownership Reporting Requirements
Starting Jan. 1, 2024, the Corporate Transparency Act and its implementing regulations mandate that certain U.S. legal entities and foreign entities registered to do business in the United States (collectively…
Continue Reading Corporate Transparency Act Takes Effect with Beneficial Ownership Reporting RequirementsSEC Division of Examinations 2024 Priorities
The Securities and Exchange Commission (SEC)’s Division of Examinations (Division) announced its 2024 examination priorities (Exam Priorities) in October. In 10 years of priority announcements, this is by far the…
Continue Reading SEC Division of Examinations 2024 PrioritiesFinCEN Extends Beneficial Ownership Reporting Deadline for Newly Formed Companies
Effective Jan. 1, 2024, the Corporate Transparency Act (CTA) will require certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) to…
Continue Reading FinCEN Extends Beneficial Ownership Reporting Deadline for Newly Formed Companies