A Texas district court has issued a nationwide preliminary injunction four weeks before a key Jan. 1, 2025, reporting deadline for the Corporate Transparency Act (CTA) that, while in effect
Continue Reading Texas Court Blocks CTA Nationwide 4 Weeks Before Key Reporting DeadlineClient Alert
FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment Advisers
On Sep. 4, 2024, FinCEN published a final rule (Final Rule) adding certain RIAs and ERAs (collectively, Covered Advisers) to the definition of “financial institution” under the regulations…
Continue Reading FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment AdvisersFTC Takes a Jab at AI-Enabled Sitejabber for Deceptive Consumer Reviews
On Nov. 6, 2024, the Federal Trade Commission (FTC) released an administrative complaint and accepted a proposed consent order resolving claims against GGL Projects, Inc., an AI-enabled customer review platform…
Continue Reading FTC Takes a Jab at AI-Enabled Sitejabber for Deceptive Consumer ReviewsFTC 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 OffersFDIC 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 AccountsCFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’
On Sept. 12, 2024, the Commodity Futures Trading Commission (CFTC) took another step toward limiting the availability and scope of relief provided by CFTC Regulation 4.7 (Reg. 4.7) under the…
Continue Reading CFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’CFPB Warns Against Deceptive Fine-Print Tactics Targeting Consumers
On June 4, 2024, the CFPB released a circular cautioning companies against including unlawful or unenforceable terms and conditions in contracts for consumer financial products or services. The circular asserts…
Continue Reading CFPB Warns Against Deceptive Fine-Print Tactics Targeting ConsumersSEC Adopts Cybersecurity Amendments to Regulation S-P
On May 16, 2024, the U.S. Securities and Exchange Commission finalized amendments to Regulation S-P (the Amendments) that largely adopt the proposed amendments the SEC issued in 2023. As discussed…
Continue Reading SEC Adopts Cybersecurity Amendments to Regulation S-PCFPB Launches Public Inquiry into Rising Mortgage Closing Costs and ‘Junk Fees’
On May 30, 2024, the CFPB issued a new request for information (RFI) from the public regarding “why closing costs are increasing, who is benefiting, and how costs for borrowers…
Continue Reading CFPB Launches Public Inquiry into Rising Mortgage Closing Costs and ‘Junk Fees’New Florida Law Creates House Bill 3 Complaint, OFR Investigation Process, and Expands Applicability to Additional Financial Institutions
On May 2, 2024, Florida Gov. Ron DeSantis held a press conference where he signed Florida House Bill 989 (HB 989 or the Bill) into law. HB 989 amends section…
Continue Reading New Florida Law Creates House Bill 3 Complaint, OFR Investigation Process, and Expands Applicability to Additional Financial Institutions