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)
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 Requirements
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
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 Parties
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 Institutions
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 Parties
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
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