Regulatory Compliance

On March 27, 2025, the Federal Trade Commission (FTC) filed a lawsuit and proposed settlement order resolving claims against Cleo AI, a fintech that operates a personal finance mobile banking application through which it offers consumers instant or same-day cash advances. The FTC alleges that Cleo deceived consumers about how much money they could get and how fast that money could be available, and that Cleo made it difficult for consumers to cancel its subscription service.
Continue Reading FTC Alleges Fintech Cleo AI Deceived Consumers

On Jan. 23, 2025, the U.S. Supreme Court granted the U.S. government’s request for a stay (SCOTUS Order) of the nationwide preliminary injunction of the Corporate Transparency Act (CTA) issued…

Continue Reading CTA UPDATE: Enforcement Remains Suspended Despite U.S. Supreme Court Granting Stay of Preliminary Injunction

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

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

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)