On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program
Continue Reading FinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements
The Consumer Financial Protection Bureau’s interpretive rule for Buy Now, Pay Later products classifies them as “credit cards” and their providers as “card issuers” and “creditors” under the Truth in
Continue Reading ‘Buy Now, Pay Later’ Rule Adds to Retailer Compliance Obligations
On Aug. 15, 2024, a federal court dismissed a proposed class action against financial analysis website Seeking Alpha, Inc. (Seeking Alpha). The lawsuit was brought in July 2023
Continue Reading No Need for Seeking Alpha to Seek Registration
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)
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 Industry
On Aug. 9, 2024, the Securities and Exchange Commission initiated administrative and cease-and-desist proceedings against a U.S. registered investment adviser (the Adviser). This action resulted from the Adviser’s failure to
Continue Reading SEC Cracks Down on Marketing Rule Violations: Takeaways for Investment Advisers
On July 30, 2024, the SEC announced it had reached a settlement agreement with Western, a dually registered investment adviser and broker-dealer providing investment advice and brokerage services to retail
Continue Reading Reg BI Enforcement Intensifies: SEC Fines Western International Securities for Violating Care and Compliance Obligations
The SEC finalized the Private Funds Rule in August 2023, imposing compliance and regulatory requirements on private fund advisers, as summarized in this GT Alert. The Private Funds Rule
Continue Reading SEC Elects Not to Request a Rehearing on Private Funds Rule
The CTA mandates that, starting on Jan. 1, 2024, certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) disclose certain BOI
Continue Reading FinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting Requirements
On June 17, 2024, the FTC filed a federal court complaint against Adobe and two of its executives. The complaint alleges that Adobe deceived consumers by failing to adequately disclose
Continue Reading FTC Targets Adobe for Hidden Fees and Deceptive Subscription Practices