Connecticut and Kansas recently joined California, New York, Florida, Utah, Virginia, and Georgia in enacting laws requiring lenders to provide consumer-like financing disclosures for certain
Continue Reading New Commercial Financing Laws Take Effect in Connecticut, KansasCompliance
2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part One of Two)
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act and related rules, absent an exemption, most private fund managers are required to register with the US Securities and Exchange…
Continue Reading 2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part One of Two)SEC Collects $390 Million in Latest Crackdown on ‘Off-Channel’ Communications in the Financial Industry
In the latest installment of its ongoing “off-channel” communications sweep, on Aug. 14, 2024, the Securities and Exchange Commission announced settlements totaling $393 million with 26 investment advisers and brokers-dealers…
Continue Reading SEC Collects $390 Million in Latest Crackdown on ‘Off-Channel’ Communications in the Financial IndustryCFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance Reports
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Final Rule (the Rule) requiring certain nonbank “covered persons” to report certain final public orders issued by a…
Continue Reading CFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance ReportsCFPB Announces New Compliance Deadlines for Small Business Lending Rule
On May 17, 2024, the CFPB announced it will issue an interim final rule to extend the compliance deadlines for its Small Business Lending Rule. When it takes effect, the…
Continue Reading CFPB Announces New Compliance Deadlines for Small Business Lending RuleCFPB Signals New FCRA Rules Targeting Data Brokers Are Ahead
On April 2, 2024, CFPB Director Rohit Chopra delivered prepared remarks at a gathering hosted by the White House Office of Science and Technology Policy. Director Chopra’s remarks centered on…
Continue Reading CFPB Signals New FCRA Rules Targeting Data Brokers Are AheadBanking Trade Groups Suing CFPB Over Late Credit Card Fees Must Transfer Case from Texas to DC
In response to the lawsuit filed by the U.S. Chamber of Commerce and bank trade groups including the Fort Worth Chamber of Commerce, Longview Chamber of Commerce, American Bankers Association…
Continue Reading Banking Trade Groups Suing CFPB Over Late Credit Card Fees Must Transfer Case from Texas to DCFinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting Requirements
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 RequirementsCFPB 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 Activities