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 ConsumersClient Alert
SEC 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 InstitutionsNevada Enacts Nation’s First State Licensing Regime for Earned Wage Access Services
On June 15, 2023, Nevada Gov. Joe Lombardo signed SB 290, establishing the nation’s first state licensing regime for earned wage access (EWA) services provided to consumers in the…
Continue Reading Nevada Enacts Nation’s First State Licensing Regime for Earned Wage Access ServicesAre Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC Views
A holding subjecting Term Loan Bs to securities regulation would have a profound effect on the $1.4 trillion market for syndicated term loans and on financial institutions at a time of limited liquidity. …
Continue Reading Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC Views
The 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties
On March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank, Santa Clara, California (SVB) and appointed the Federal Deposit Insurance Corporation (FDIC) as receiver…
Continue Reading The 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesSEC Announces 2023 Examination Priorities
On Feb. 7, 2023, the Securities and Exchange Commission’s Division of Examinations announced its 2023 examination priorities. The announcement focuses on six different categories.
Continue reading the full GT Alert.
Continue Reading SEC Announces 2023 Examination PrioritiesDanske Bank Pleads Guilty, Agrees to Pay More Than $2 Billion in Coordinated Resolution of Investigations into Fraud Related to Its Anti-Money Laundering Controls
On Dec. 13, 2022, the Department of Justice announced that Danish global financial institution Danske A/S (Danske Bank) pled guilty and agreed to forfeit $2 billion to resolve an investigation…
Continue Reading Danske Bank Pleads Guilty, Agrees to Pay More Than $2 Billion in Coordinated Resolution of Investigations into Fraud Related to Its Anti-Money Laundering ControlsBeneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency Act
On Sept. 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule, effective Jan. 1, 2024, implementing the beneficial ownership information reporting…
Continue Reading Beneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency Act