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 DeadlineRegulatory Compliance
FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment Advisers
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 AdvisersFTC Takes a Jab at AI-Enabled Sitejabber for Deceptive Consumer Reviews
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 Reviews2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part Two of Two)
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)CFPB Issues Personal Financial Data Rights Rule
On Oct. 22, 2024, the CFPB issued a final rule that will require covered financial institutions to provide consumers and authorized third parties with access and portability options for their…
Continue Reading CFPB Issues Personal Financial Data Rights RuleLawsuit Challenges CFPB’s ‘Buy Now, Pay Later’ Rule
On Oct. 18, 2024, fintech trade group Financial Technology Association (FTA) filed a lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB) final interpretative rule on “Buy Now, Pay Later” (BNPL)…
Continue Reading Lawsuit Challenges CFPB’s ‘Buy Now, Pay Later’ RuleSEC Division of Examinations 2025 Priorities
The Securities and Exchange Commission’s Division of Examinations (Division) announced its 2025 examination priorities (Exam Priorities) Oct. 21, 2024. These priorities address areas of concern based on recent examinations, and…
Continue Reading SEC Division of Examinations 2025 PrioritiesFDIC Proposes New Requirements for Custodial Accounts
On Oct. 2, 2024, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking (Proposed Rule) designed to strengthen recordkeeping requirements for custodial deposit accounts with transactional features…
Continue Reading FDIC Proposes New Requirements for Custodial AccountsCTA Countdown: Upcoming FinCEN Filing Deadlines
The Corporate Transparency Act (CTA) has been in effect since Jan. 1, 2024, requiring non-exempt U.S. entities and non-exempt foreign entities that are registered to do business in the United…
Continue Reading CTA Countdown: Upcoming FinCEN Filing DeadlinesCFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’
On Sept. 12, 2024, the Commodity Futures Trading Commission (CFTC) took another step toward limiting the availability and scope of relief provided by CFTC Regulation 4.7 (Reg. 4.7) under the…
Continue Reading CFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’