The Consumer Financial Protection Bureau’s interpretive rule for Buy Now, Pay Later products classifies them as “credit cards” and their providers as “card issuers” and “creditors” under the Truth in
Continue Reading ‘Buy Now, Pay Later’ Rule Adds to Retailer Compliance Obligations
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)
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Final Rule (the Rule) requiring certain nonbank “covered persons” to report certain final public orders issued by a
Continue Reading CFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance Reports
On May 17, 2024, the CFPB announced it will issue an interim final rule to extend the compliance deadlines for its Small Business Lending Rule. When it takes effect, the
Continue Reading CFPB Announces New Compliance Deadlines for Small Business Lending Rule
On July 14, 2022, the U.S. House of Representatives passed bipartisan legislation that, if passed by the Senate and signed into law, would expand the types of institutions required to
Continue Reading ENABLERS Act Proposes to Expand Definition of ‘Financial Institution’; Impose BSA/AML Requirements on Professional Service Providers
The Consumer Financial Protection Bureau (CFPB) has begun information-gathering inquiries into multiple companies that offer “buy now, pay later” (BNPL) credit to merchants and consumers, citing concerns about “accumulating debt,
Continue Reading CFPB Begins Scrutinizing Companies Using ‘Buy Now, Pay Later’ Credit
On Oct. 26, 2021, the Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert in which it identified observations from examinations under its registered investment company initiative,
Continue Reading SEC Issues Risk Alert Regarding Registered Investment Companies
On Oct. 23, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (FRB) (FinCEN and the FRB
On Sept. 25, 2020, the SEC issued a No-Action Letter to FINRA, in response to a previously issued Joint Statement by the SEC and FINRA. This No-Action Letter detailed how
Continue Reading SEC Issues No-Action Letter Facilitating the Secondary Trading of Digital Assets
Welcome to the inaugural issue of Greenberg Traurig’s Financial Services Insights. The impact of Coronavirus Disease 2019 (COVID-19) has been both unexpected and devastating. As the economic fallout spreads, financial