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

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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 Deadlines

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

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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

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

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 Industry

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 Advisers