Client Alert

A dispute between the city of Baltimore and Dave Inc. (Dave) raises questions about the scope of local consumer-protection authority and its relationship to Maryland’s statewide consumer-lending framework. Dave has…

Continue Reading Dave Challenges Baltimore’s Authority to Enforce Consumer Protection Ordinance Against Cash-Advance Products

The Federal Trade Commission has settled with a payment processor and four affiliated entities over allegations that the companies knowingly enabled deceptive merchants, including foreign tech-support operations, to access the…

Continue Reading FTC Announces Settlement and Articulates Knowledge Standard for Payment-Processor Liability

The Federal Trade Commission has reached a proposed $12 million settlement with Humboldt Merchant Services based on allegations that it processed payments for merchants that were shell companies or engaged…

Continue Reading FTC Targets Payment Processor in Proposed $12 Million Sham-Merchant Settlement

On August 12, 2026, the SEC’s Division of Investment Management issued a No-Action Letter (the Letter) granting no-action relief to Franklin Templeton under Section 17(f) of the Investment Company Act of 1940 (the 1940 Act) and Rule 17f-2.…

Continue Reading SEC Staff Grants No-Action Relief for Digital Asset Custody

On Aug. 5, 2026, the Securities and Exchange Commission announced a new specialized unit within its Division of Enforcement focused on accounting and financial reporting fraud, as well as broader misconduct in the accounting and auditing areas.…

Continue Reading SEC Creates Financial Reporting and Accounting Unit in Enforcement Division

In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.”…
Continue Reading Federal and State Efforts Intensify Focus on ‘Debanking’

In October’s GT Alert on non-bank lending, we focussed on whether there was a justification in banks being subject to regulatory capital requirements when non-bank financial institutions (NBFIs) were not.

Continue Reading Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?

On Sept. 30, 2025, the OFR requested approval from the Florida Financial Services Commission to publish a Notice of Proposed Rule to amend Rules 69U-100.323 and 69U-100.3231 and for final…

Continue Reading Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking Rules

On Sep. 8, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it issued a new Geographic Targeting Order (September GTO) that renewed and modified FinCEN’s GTO announced on March 11, 2025 (March GTO).
Continue Reading Deadline Quickly Approaching for Newly Covered MSBs To Comply with FinCEN’s Southwest Border GTO

On June 16, 2025, the Senate Finance Committee released its own version of the tax provisions of H.R. 1, entitled the “One Big Beautiful Bill Act,” which the U.S. House of Representatives passed on May 22, 2025. The full U.S. Senate is expected to debate the Senate Proposal in the days ahead, where additional changes may be made.
Continue Reading One Big Beautiful Bill Act – Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers Abroad