In October 2024, the California DFPI finalized regulations for providers of income-based advances (Earned Wage Access or EWA), clarifying registration requirements under the California Consumer Financial Protection Law (CCFPL). These
Continue Reading California DFPI Finalizes New Earned Wage Access Regulations
The Commodity Futures Trading Commission (CFTC) undertook a series of initiatives in 2024 to address CFTC registrants’ and other industry participants’ use and application of AI technologies. While these actions
Continue Reading Reviewing 2024 CFTC AI Initiatives and Looking Ahead
On Dec. 26, 2024, the nationwide preliminary injunction that a Texas district court issued in Texas Top Cop Shop, Inc. v. Garland against enforcement of the Corporate Transparency Act (CTA)
Continue Reading CTA Update: Nationwide Preliminary Injunction Against CTA Reinstated
On Nov. 21, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule), pursuant to 12 U.S.C. § 5514(a)(1)(B), to establish supervisory authority over nonbank entities identified as
Continue Reading CFPB’s Final Rule Enhancing Oversight of Large Digital Payment App Providers Goes into Effect Jan. 9 – Are You Ready?
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 Deadline
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 Advisers
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 Reviews
On Nov. 18, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a 45-day extension to the public comment period for its proposed rule making (Proposed Rule) that would establish new
Continue Reading FDIC Extends Comment Period for New Requirements for Custodial Accounts
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)
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 Statutes