On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Interpretive Rule and Request for Comment (Proposed Rule) addressing credit products in the paycheck advance marketplace, such
Continue Reading CFPB Proposes Interpretive Rule for Earned Wage Access ProductsFinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements
On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program…
Continue Reading FinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements‘Buy Now, Pay Later’ Rule Adds to Retailer Compliance Obligations
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 ObligationsNo Need for Seeking Alpha to Seek Registration
On Aug. 15, 2024, a federal court dismissed a proposed class action against financial analysis website Seeking Alpha, Inc. (Seeking Alpha). The lawsuit was brought in July 2023…
Continue Reading No Need for Seeking Alpha to Seek RegistrationSEC Collects $390 Million in Latest Crackdown on ‘Off-Channel’ Communications in the Financial Industry
In the latest installment of its ongoing “off-channel” communications sweep, on Aug. 14, 2024, the Securities and Exchange Commission announced settlements totaling $393 million with 26 investment advisers and brokers-dealers…
Continue Reading SEC Collects $390 Million in Latest Crackdown on ‘Off-Channel’ Communications in the Financial IndustrySEC Cracks Down on Marketing Rule Violations: Takeaways for Investment Advisers
On Aug. 9, 2024, the Securities and Exchange Commission initiated administrative and cease-and-desist proceedings against a U.S. registered investment adviser (the Adviser). This action resulted from the Adviser’s failure to…
Continue Reading SEC Cracks Down on Marketing Rule Violations: Takeaways for Investment AdvisersSEC Elects Not to Request a Rehearing on Private Funds Rule
The SEC finalized the Private Funds Rule in August 2023, imposing compliance and regulatory requirements on private fund advisers, as summarized in this GT Alert. The Private Funds Rule…
Continue Reading SEC Elects Not to Request a Rehearing on Private Funds RuleFinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting Requirements
The CTA mandates that, starting on Jan. 1, 2024, certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) disclose certain BOI…
Continue Reading FinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting RequirementsFTC 2023 Enforcement Highlights: A Closer Look at Auto Financing, Electronic Fund Transfers, and Consumer Leasing
Go-To Guide:
- The Federal Trade Commission (FTC)’s 2023 annual report highlights significant enforcement actions and educational efforts, focusing on consumer protection under the Truth in Lending Act (TILA), Consumer Leasing
CFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance Reports
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