On Nov. 5, 2024, the Federal Trade Commission (FTC) filed a lawsuit against Dave, Inc., a U.S. fintech company that offers short-term cash advances through a mobile banking application. The
Continue Reading FTC Alleges Fintech Dave, Inc. Deceived ConsumersSEC 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 PrioritiesCTA 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 DeadlinesCFPB Proposes Interpretive Rule for Earned Wage Access Products
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 Rule