By a 3-2 party-line vote, on Aug. 23, 2023, the Securities and Exchange Commission adopted some of the most significant new rules under the Investment Advisers Act of 1940, as
Continue Reading Private Fund Adviser Rulemaking
News & Commentary on Financial Regulatory and Compliance Matters
By a 3-2 party-line vote, on Aug. 23, 2023, the Securities and Exchange Commission adopted some of the most significant new rules under the Investment Advisers Act of 1940, as…
Continue Reading Private Fund Adviser RulemakingOn March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank, Santa Clara, CA (SVB) and appointed the Federal Deposit Insurance Corporation (FDIC) receiver of…
Continue Reading The 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesThis GT Alert provides a general overview for investors interested in acquiring or investing in the assets of failed depository institutions and requirements and restrictions applicable to private investors’ participation…
Continue Reading The 2023 Banking Crisis: Guidance for Private Investors Seeking to Acquire or Invest in Assets of Failed Insured Depository InstitutionsOn 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 PartiesOn Dec. 6, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on potential requirements…
Continue Reading FinCEN Launches Rulemaking Process to Implement Reporting Requirements for Real Estate Sector
As the COVID-19 situation continues to evolve, market volatility, workplace disruptions and a shuttering of everyday life are becoming increasingly commonplace. While the 2021 LIBOR phase-out may not seem top…
Continue Reading All Systems Go? LIBOR Transition Efforts During the COVID-19 Pandemic
On Jan. 31, 2018, the U.S. Court of Appeals for the District of Columbia Circuit issued its long-awaited ruling in the PHH v. Consumer Financial Protection Bureau case, finding that…
Continue Reading D.C. Circuit Court of Appeals Rules that CFPB Structure is Constitutional, but Rejects the CFPB’s Interpretations of RESPA
Jennifer L. Gray, co-chair of the Consumer Financial Services Litigation Practice, will be speaking at the 2017 Mortgage Bankers Association (MBA) Legal Issues & Regulatory Compliance (LIRC) Conference.
Continue Reading Jennifer Gray to Speak at MBA Legal Issues & Regulatory Compliance Conference
On Feb. 23, 2017, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) extended by an additional six months its existing Geographic Targeting Orders (GTOs) that…
Continue Reading High-End, Cash-Only Real Estate Sales in Six Major Metropolitan Areas Remain Subject to Mandatory AML Reporting Requirements
On July 27, 2016, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued a press release announcing new Geographic Targeting Orders (GTOs) applicable to certain…
Continue Reading U.S. Treasury Department Expands its ‘Real Estate GTOs’ to Require Title Insurance Companies and Their Agents To Report the Ultimate Beneficial Owners of Entities Used To Buy Residential Real Estate in All-Cash Purchases in Six Metropolitan Areas, Including all of New York City, South Florida and Portions of California and Texas