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 RequirementsReal Estate
Private Fund Adviser Rulemaking
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 RulemakingThe 2023 Banking Crisis: Updated 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, 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 PartiesThe 2023 Banking Crisis: Guidance for Private Investors Seeking to Acquire or Invest in Assets of Failed Insured Depository Institutions
This 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 InstitutionsThe 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 PartiesFinCEN Launches Rulemaking Process to Implement Reporting Requirements for Real Estate Sector
On 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
All Systems Go? LIBOR Transition Efforts During the COVID-19 Pandemic
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
D.C. Circuit Court of Appeals Rules that CFPB Structure is Constitutional, but Rejects the CFPB’s Interpretations of RESPA
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 Gray to Speak at MBA Legal Issues & Regulatory Compliance Conference
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
High-End, Cash-Only Real Estate Sales in Six Major Metropolitan Areas Remain Subject to Mandatory AML Reporting Requirements
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