This article covers the standard compliance policies and procedures that real estate fund managers should consider adopting, whether in consultation with attorneys who have experience with registered investment advisers (RIAs)
Continue Reading 2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part Two of Two)CFPB Urges States to Fill Gaps in Federal Financial Privacy Statutes
On Nov. 12, 2024, the Consumer Financial Protection Bureau (CFPB) released a report examining federal and state privacy protections for consumers’ financial data. In the report, the CFPB “critiques” the…
Continue Reading CFPB Urges States to Fill Gaps in Federal Financial Privacy StatutesFTC Alleges Fintech Dave, Inc. Deceived Consumers
On Nov. 5, 2024, the Federal Trade Commission (FTC) filed a lawsuit against Dave, Inc., a U.S. fintech company that offers short-term cash advances through a mobile banking application. The…
Continue Reading FTC Alleges Fintech Dave, Inc. Deceived ConsumersCFPB Issues Personal Financial Data Rights Rule
On Oct. 22, 2024, the CFPB issued a final rule that will require covered financial institutions to provide consumers and authorized third parties with access and portability options for their…
Continue Reading CFPB Issues Personal Financial Data Rights RuleFlorida Amends Securities and Investor Protection Act: Key Changes to Private Placement, Institutional Investor Exemptions
Regulations amending Chapter 517 of the Florida Securities and Investor Protection Act (FSIPA) took effect Oct. 1, 2024 (the Regulations). While the Regulations revise certain existing securities and transactional exemptions…
Continue Reading Florida Amends Securities and Investor Protection Act: Key Changes to Private Placement, Institutional Investor ExemptionsSEC Files Actions Against 4 Public Companies for Negligent Cybersecurity Disclosures
On Oct. 22, 2024, the SEC announced settled administrative actions against four current or formerly public technology companies, finding that the companies all made materially misleading disclosures to investors in…
Continue Reading SEC Files Actions Against 4 Public Companies for Negligent Cybersecurity DisclosuresLawsuit Challenges CFPB’s ‘Buy Now, Pay Later’ Rule
On Oct. 18, 2024, fintech trade group Financial Technology Association (FTA) filed a lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB) final interpretative rule on “Buy Now, Pay Later” (BNPL)…
Continue Reading Lawsuit Challenges CFPB’s ‘Buy Now, Pay Later’ RuleFTC Announces Final ‘Click-to-Cancel’ Rule for Subscription Services and Other Negative Option Offers
On Oct. 16, 2024, the Federal Trade Commission announced its final “Click-to-Cancel” Rule for subscription services and other negative option offers. The rule requires sellers to make it as easy…
Continue Reading FTC Announces Final ‘Click-to-Cancel’ Rule for Subscription Services and Other Negative Option OffersSEC Division of Examinations 2025 Priorities
The Securities and Exchange Commission’s Division of Examinations (Division) announced its 2025 examination priorities (Exam Priorities) Oct. 21, 2024. These priorities address areas of concern based on recent examinations, and…
Continue Reading SEC Division of Examinations 2025 PrioritiesFDIC Proposes New Requirements for Custodial Accounts
On Oct. 2, 2024, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking (Proposed Rule) designed to strengthen recordkeeping requirements for custodial deposit accounts with transactional features…
Continue Reading FDIC Proposes New Requirements for Custodial Accounts