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Financial Services Observer

News & Commentary on Financial Regulatory and Compliance Matters

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11th Circuit

11th Circuit Answers When Would-Be ‘Customers’ May Bring a FINRA Arbitration Against FINRA Members and Associated PersonsFDCPA – 11TH Circuit: Kinlock v. Wells Fargo Bank – Post-Foreclosure Offers of Financial Assistance to Defaulted Borrower Not Violative of FDCPA/Florida Consumer Collection Protection Act

2d Circuit

Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsSCOTUS to Resolve Circuit Split Over Dodd-Frank Whistleblowers

account freezing order

Prove It or Lose It! Part III: A Step Too Far? Account Freezing Orders & Account Forfeiture Orders in the UK

annuity

Illinois Supreme Court Rules Annuities Are Not Securities Under Illinois Securities Act

anti-bribery

UK Review of the Bribery Act 2010 – Committee Concludes New Guidance Needed

Anti-Money Laundering

FinCEN Postpones Effective Date of Investment Adviser AML Rule and Announces Intent to Revisit Its ScopeOne Big Beautiful Bill Act - Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers AbroadCharges Dropped Against Early Cryptocurrency Exchange Operator

Appointed Representatives Regime

Principals in the Spotlight as UK’s FCA Consults on Changes to Appointed Representatives Regime

Arbitration

Outlook 2026: Financial Services Litigation5 Trends to Watch: 2025 Financial Services Litigation5 Trends to Watch: 2024 Financial Services Litigation

banking

Federal and State Efforts Intensify Focus on ‘Debanking’Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking Rules

Banking Regulators

Federal and State Efforts Intensify Focus on ‘Debanking’Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for BanksSupreme Court Hears Oral Argument on Constitutionality of CFPB’s Funding

Bankruptcy

Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsThe 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

Banks

Federal and State Efforts Intensify Focus on ‘Debanking’UK FCA Expands the Reach of COCON and Consults on Non-Financial MisconductOne Big Beautiful Bill Act - Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers Abroad

BitLicense

The OCC and SEC’s FinHub Issue Guidance on Fiat-Backed Stablecoin ReservesNew York State Department of Financial Services Proposes Framework for a Conditional BitLicenseNew York State Releases Final BitLicense Regulation

Blockchain

SEC Approves In-Kind Creations and Redemptions for Crypto ETPsOne Big Beautiful Bill Act - Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers AbroadFederal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks

Blockchain Technology Task Force

Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering ViolationsFlorida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the StateFinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset Transactions

Brokers

Path Cleared for Registered Representative-Owned PSEs To Receive Transaction-Based CompensationNov. 2 EVENT | Selecting an EB-5 Investment ProjectProposed Legislation Would Create a Tiered Exemption from Broker Registration

California

California DFPI Issues Formal Rulemaking for Digital Financial Asset RegulationEffective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200California DFPI Finalizes New Earned Wage Access Regulations

Capital Markets

Florida Amends Securities and Investor Protection Act: Key Changes to Private Placement, Institutional Investor ExemptionsSEC Chair Continues Push to Regulate Digital Asset MarketsSEC Proposes Rule Changes to Mutual Fund and Exchange Traded Fund Disclosures

CFPB

CFPB Withdraws ‘Fine Print’ RuleCFPB Proposes to Narrow Risk-Based SupervisionCFPB Reopens Its Open Banking Rule for Comment

CFTC

CFTC Issues Enforcement Advisory on Benefits of Self-Reporting, Cooperation, and RemediationReviewing 2024 CFTC AI Initiatives and Looking AheadCFTC Further Narrows Scope of Relief Under Regulation 4.7 'Registration Lite'

Class Action Litigation

Financial Services Insights | Summer 2020Tyson Foods, Inc. v. Bouaphakeo: Supreme Court Upholds Use of Statistical Evidence in Class Actions

Client Alert

Federal and State Efforts Intensify Focus on ‘Debanking’Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking Rules

Commodities

CFTC Issues Enforcement Advisory on Benefits of Self-Reporting, Cooperation, and RemediationCFTC Cancels and Replaces Proposed Regulation ATCFTC Proposes Expanding Exemption for Non-U.S. Commodity Pool Operators

Compliance

Path Cleared for Registered Representative-Owned PSEs To Receive Transaction-Based CompensationUK FCA Expands the Reach of COCON and Consults on Non-Financial MisconductUS Treasury Extends Recordkeeping Requirement for Economic Sanctions Compliance to 10 Years

Consumer Financial Services

CFPB Withdraws ‘Fine Print’ RuleFlorida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking RulesFTC Alleges Fintech Cleo AI Deceived Consumers

Consumer Lending

CFPB Plans Personal Lender Oversight, Funds Access RulesCFPB Launches Public Inquiry into Rising Mortgage Closing Costs and ‘Junk Fees’Small Business Lenders: CFPB Issues Final Rule on Small Business Lending

convertible virtual currency

Florida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the StateFinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset TransactionsSEC Issues No-Action Letter Facilitating the Secondary Trading of Digital Assets

coronavirus

CFPB Metrics Report Shows Increased Scrutiny of Borrower Access to Servicers, Information, and Loss Mitigation OpportunitiesPaycheck Protection Program – Expected Impact of ‘Second Draw’ LoansFinancial Services Insights | Summer 2020

Corporate Governance

Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting RequirementsSEC Proposes Exemption from Registration for FindersCOVID-19 Pandemic: Banking & Finance ‘Phase 2’ Measures in Italy

cryptocurrency

Outlook 2026: Financial Services LitigationSEC Approves In-Kind Creations and Redemptions for Crypto ETPsFederal Banking Regulators Issue Guidance on Risk Management for Crypto-Asset Safekeeping Activities

Cyberattack

SEC Clarifies Confusion Concerning Cybersecurity Incident Reporting

Cybersecurity

NYDFS Final Cybersecurity Rules – MFA, Asset Inventory, and Third-Party RiskSEC Files Actions Against 4 Public Companies for Negligent Cybersecurity DisclosuresSEC Clarifies Confusion Concerning Cybersecurity Incident Reporting

Debt

CFPB Begins Scrutinizing Companies Using ‘Buy Now, Pay Later’ Credit

Debt relief

Financial Services Insights | Summer 2020Congress Passes the PPP Flexibility ActFCC Proposes Rules to Limit the Use of Robocalls to Collect Debts Owed to or Guaranteed by the United States

Digital Assests

Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for BanksCalifornia DFPI Issues Formal Rulemaking for Digital Financial Asset RegulationFinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing

Digital Assets

SEC Approves In-Kind Creations and Redemptions for Crypto ETPsSEC Staff Clarifies Stance on Crypto MiningSEC Clarifies Stance: Most Meme Coins Not Subject to Securities Regulation

digital wallets

CFPB’s Final Rule Enhancing Oversight of Large Digital Payment App Providers Goes into Effect Jan. 9 – Are You Ready?CFPB Unveils Plan to Supervise Big Tech Digital Wallet and Payment App Providers

Dodd-Frank

2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part Two of Two)2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part One of Two)CFPB Issues ‘Fast Facts’ for Proposed Personal Financial Data Rights Rule

Due Diligence

Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for BanksFinCEN Finalizes Customer Due Diligence RuleDue Diligence Outsourcing: Traps for the Unwary

Earned Wage Access Services

California DFPI Finalizes New Earned Wage Access RegulationsMontana Attorney General Confirms Certain Earned Wage Access Products Are Not LoansMaryland Office of Financial Regulation Provides Guidance on Earned Wage Access Products

EB-5

SEC Disgorgement Lives to See Another Day After Supreme Court’s Liu v. SEC RulingNot Every Broker-Dealer is an EB-5 Broker-DealerSEC Charges Attorneys Across the Country for Acting as Unlicensed Securities Brokers

economic sanctions

US Treasury Extends Recordkeeping Requirement for Economic Sanctions Compliance to 10 YearsExpansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce InsightsCrypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations

EU's Bank Recovery and Resolution Directive

Derivatives Update: What You Should Know As We Enter 2017Article 55 BRRD Can Impact Your Company

European Union

LIBOR Transition Newsletter – Issue 1LIBOR and “No-Deal” BrexitEU Proposes New Rules to Manage Leverage and Derivative Exposure for Funds – Are Asset Managers Ready?

Events

Nov. 2 EVENT | Selecting an EB-5 Investment ProjectWebinar – Aug. 20: LIBOR Phaseout - Preparing for the Beginning of the EndGreenberg Traurig’s Nanette Aguirre to Speak at Florida Alternative Investment Association Global Macro Perspective 2018

Exchange-Traded Funds (ETFs)

5 Trends to Watch: 2025 Futures & DerivativesSEC Proposes Rule Changes to Mutual Fund and Exchange Traded Fund DisclosuresSEC Passes Long-Awaited New Rule 6c-11 to Modernize Regulation of ETFs

Exempt offerings

SEC Issues Concept Release to Overhaul Current Framework for Exempt Offerings

FCA

Outlook 2026: Financial Services LitigationUK FCA Expands the Reach of COCON and Consults on Non-Financial MisconductFCA Review of Private Fund Market Valuation Practices

FDIC

Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for BanksUS Fair Access and Anti-Debanking Laws: What to Expect Under the New AdministrationFDIC Extends Comment Period for New Requirements for Custodial Accounts

Featured

SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement PrioritiesFederal and State Efforts Intensify Focus on ‘Debanking’CTA UPDATE: Eleventh Circuit Declares CTA Constitutional; Beneficial Ownership Reporting Requirements Remain Unchanged

Federal Reserve System

Federal Reserve Rate Cut Prompts Demand for Derivative Hedging SolutionsFederal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for BanksFed Issues Proposed Rule Lowering Regulation II’s Debit Interchange Cap

Financial Conduct Authority

UK FCA Expands the Reach of COCON and Consults on Non-Financial MisconductUK FCA Letter Expresses Concerns About Fund Service ProvidersUK FCA Proposes Changes to Safeguarding Regime for Payments and E-Money Firms

Financial Crimes Enforcement Network

CTA UPDATE: Eleventh Circuit Declares CTA Constitutional; Beneficial Ownership Reporting Requirements Remain UnchangedDeadline Quickly Approaching for Newly Covered MSBs To Comply with FinCEN's Southwest Border GTOFinCEN Postpones Effective Date of Investment Adviser AML Rule and Announces Intent to Revisit Its Scope

Financial Regulation

Outlook 2026: Financial Services LitigationFederal and State Efforts Intensify Focus on ‘Debanking’CTA UPDATE: Eleventh Circuit Declares CTA Constitutional; Beneficial Ownership Reporting Requirements Remain Unchanged

Financial Services Litigation

Outlook 2026: Financial Services LitigationFederal and State Efforts Intensify Focus on ‘Debanking’5 Trends to Watch: 2025 Financial Services Litigation

FINRA

Outlook 2026: Financial Services LitigationProviding Useful Tools: FINRA Releases its 2026 Annual Regulatory Oversight Report, Together with a FINRA Unscripted Podcast Filled with Senior Leadership InsightsWith an Eye Toward Modernization, FINRA Requests Comment on Its Regulatory Requirements for Members and Associated Persons

Fintech

CFPB Memo Details Less Oversight on Fintechs, Shift to State-Led EnforcementFTC Alleges Fintech Cleo AI Deceived ConsumersThe Current And Future State Of Bank-Fintech Partnerships

Firm News

Greenberg Traurig’s Carl Fornaris and William Mack Participate at FMA’s Legal and Legislative Issues ConferenceNanette Aguirre to Speak at the Meeting of the Americas 2017 ConferenceNanette Aguirre Joins Board of Florida Alternative Investment Association

First Circuit

First Circuit Offers Rebuke to SEC in Vacating Sanctions Order

Florida

Federal and State Efforts Intensify Focus on ‘Debanking’Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking RulesFlorida Amends Securities and Investor Protection Act: Key Changes to Private Placement, Institutional Investor Exemptions

FLSA

Tyson Foods, Inc. v. Bouaphakeo: Supreme Court Upholds Use of Statistical Evidence in Class Actions

foreclosure

The Ninth Circuit Issued a Ruling in Bourne Valley Court Trust v. Wells Fargo Bank, NAThird District Court of Appeals Reverses Holding on Statute of Limitations for Florida Foreclosures: The Impact of Deutsche Bank Trust Company Americas, as Trustee v. Beauvais

FSOC

Digital Assets: Financial Stability Oversight Council Risk Report Assesses Regulatory Gaps; Offers RecommendationsFSOC Report Targets Marketplace LendingFinancial Stability Oversight Council Releases 2016 Annual Report

FTC

FTC Issues FAQs on ‘Junk Fees’ Rule

Gaming

GT’s Carl Fornaris Moderates Panel at IAGA, Featured in Gambling ComplianceGreenberg Traurig to Participate at the FIBA Anti-Money Laundering Compliance Conference10 TRENDS: Getting Better All the Time

Global

SEC Finalizes Cyber Rules for Public Companies: What You Need to KnowFinCEN and BIS Warn Financial Institutions About Potential Evasion of Russian and Belarusian Export ControlsCOVID-19 Pandemic: Banking & Finance ‘Phase 2’ Measures in Italy

Government

One Big Beautiful Bill Act - Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers AbroadNY Gov Signs Amended LLC Transparency ActNew Florida Legislation Proposes Notification Requirements for Certain Financial Institutions When They Terminate, Suspend, or Take Similar Action to ‘Restrict’ Customer Account Access

GT Alert

SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement PrioritiesOutlook 2026: Financial Services LitigationFederal and State Efforts Intensify Focus on ‘Debanking’

Insurance

GT Recap | NAIC Fall 2020 National MeetingIllinois Supreme Court Rules Annuities Are Not Securities Under Illinois Securities ActFred Karlinsky, Rich Fidei, and Jamey Zellner Co-Author Cybersecurity Update in Reactions Magazine

insurance producer

Illinois Supreme Court Rules Annuities Are Not Securities Under Illinois Securities Act

investment advisor

U.S. Appeals Court Vacates SEC Private Fund Adviser RuleSEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting DocumentsUpdating and Improving the UK Asset Management Regime: An FCA Discussion Paper

Investment Company Act of 1940

U.S. Appeals Court Vacates SEC Private Fund Adviser RuleSEC Issues Risk Alert Regarding Registered Investment CompaniesSEC Staff Issues No-Action Relief for Custody of Certain Loan Interests Under the Investment Company Act

Investment Regulation

Florida Amends Securities and Investor Protection Act: Key Changes to Private Placement, Institutional Investor ExemptionsFinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program RequirementsSEC Cracks Down on Marketing Rule Violations: Takeaways for Investment Advisers

Lending

Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?New Commercial Financing Laws Take Effect in Connecticut, KansasCFPB Announces New Compliance Deadlines for Small Business Lending Rule

LIBOR

2021 SEC Examination Priorities for Securities Industry RegistrantsFinancial Services Insights | Summer 2020Webinar – Aug. 20: LIBOR Phaseout - Preparing for the Beginning of the End

Litigation

Outlook 2026: Financial Services LitigationSEC Files Actions Against 4 Public Companies for Negligent Cybersecurity DisclosuresCTA Countdown: Upcoming FinCEN Filing Deadlines

Mortgage

CFPB Launches Public Inquiry into Rising Mortgage Closing Costs and ‘Junk Fees’CFPB Issues Report on Unlawful ‘Junk Fees’ Uncovered in Deposit Accounts, Multiple Loan Servicing MarketsCFPB Metrics Report Shows Increased Scrutiny of Borrower Access to Servicers, Information, and Loss Mitigation Opportunities

Nevada

Nevada Enacts Nation’s First State Licensing Regime for Earned Wage Access Services

New York

NYDFS Final Cybersecurity Rules – MFA, Asset Inventory, and Third-Party RiskAmended New York Transparency Act Broadens Entity Reporting Obligations Beyond Federal StandardsNew York Enacts Landmark ‘Buy Now, Pay Later’ Regulation Amid Federal Regulatory Recalibration

nonbanks

Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?Non-Bank Lending in the Spotlight: Regulatory Capital and Its ImpactCFPB Unveils Plan to Supervise Big Tech Digital Wallet and Payment App Providers

OCIE

2020 SEC Exam Priorities for Securities Industry RegistrantsSEC Publishes OCIE 2020 Examination PrioritiesSEC’s Office of Compliance Inspections and Examinations Releases 2019 Examination Priorities

Office of the Comptroller of the Currency

Federal and State Efforts Intensify Focus on ‘Debanking’Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for BanksUS Fair Access and Anti-Debanking Laws: What to Expect Under the New Administration

President Trump's Administration

Federal and State Efforts Intensify Focus on ‘Debanking’Congress Abolishes Certain Exemptions for Foreign Private Issuers; Will Now Require Compliance with Section 16(a) Beneficial Ownership Reporting For Directors and OfficersFederal Reserve Rate Cut Prompts Demand for Derivative Hedging Solutions

PWG

President’s Working Group on Financial Markets Releases Report and Recommendations on Stablecoins

Real Estate

2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part Two of Two)2024 Update: Best-Practice Compliance Policies for Real Estate Fund Managers (Part One of Two)FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting Requirements

Regulatory

Outlook 2026: Financial Services LitigationOne Big Beautiful Bill Act - Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers AbroadWith an Eye Toward Modernization, FINRA Requests Comment on Its Regulatory Requirements for Members and Associated Persons

Regulatory Compliance

Federal and State Efforts Intensify Focus on ‘Debanking’NYDFS Final Cybersecurity Rules – MFA, Asset Inventory, and Third-Party RiskFlorida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking Rules

Regulatory Decisions Committee

UK FCA Implements Controversial Change to Its Decision-Making Procedures

Retirement

NY Department of Financial Services Proposes its Own Fiduciary Rule in Response to U.S. DOL DelayProposed Fiduciary Rule for Retirement Accounts One Step Closer to Reality

Risk

2023 Report on FINRA’s Examination and Risk Monitoring ProgramFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsNYDFS Proposes Significant Changes to Its Cybersecurity Regulation

Risk Management

Federal and State Efforts Intensify Focus on ‘Debanking’Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking RulesFTC Alleges Fintech Dave, Inc. Deceived Consumers

Sarbanes-Oxley Act

SCOTUS Rules Dodd-Frank Does Not Protect Internal WhistleblowingNinth Circuit Widens Circuit Split on Whether Dodd-Frank Protects Internal Whistleblowing

SEC

SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement PrioritiesSEC Division of Examinations 2026 PrioritiesPath Cleared for Registered Representative-Owned PSEs To Receive Transaction-Based Compensation

Securities

SEC Staff Clarifies Stance on Crypto MiningSEC Clarifies Stance: Most Meme Coins Not Subject to Securities RegulationFlorida Amends Securities and Investor Protection Act: Key Changes to Private Placement, Institutional Investor Exemptions

Securities and Exchange Commission

SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement PrioritiesSEC Division of Examinations 2026 PrioritiesPath Cleared for Registered Representative-Owned PSEs To Receive Transaction-Based Compensation

small businesses

CFPB Announces New Compliance Deadlines for Small Business Lending RuleCourt Issues Nationwide Stay of CFPB’s Section 1071 Small Business Lending RuleSmall Business Lenders: CFPB Issues Final Rule on Small Business Lending

Social & Governance (ESG)

Federal and State Efforts Intensify Focus on ‘Debanking’SEC Issues Long-Awaited Proposed Rule on Climate Disclosures

Stablecoin

CFPB And FTC Take Their Place As Powerful Crypto CopsFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsSEC Chair Continues Push to Regulate Digital Asset Markets

State and Local

Federal and State Efforts Intensify Focus on ‘Debanking’NYDFS Final Cybersecurity Rules – MFA, Asset Inventory, and Third-Party RiskAmended New York Transparency Act Broadens Entity Reporting Obligations Beyond Federal Standards

sustainable finance

OCC Final Rule Modernizing the Community Reinvestment Act Includes New Incentives for Investing in Indian Country

Tax

One Big Beautiful Bill Act - Senate Proposal Would Limit Applicability of House’s 3.5% Remittance Tax on Fund Transfers AbroadIRS Issues New Cryptocurrency GuidanceSEC Issues ‘No-Action’ Letters Allowing Sales of Utility Tokens

TCPA

Greenberg Traurig’s Gil Rudolph and Lori S. Nugent Participate at CCFL’s Annual Consumer Financial Services ConferenceFCC Proposes Rules to Limit the Use of Robocalls to Collect Debts Owed to or Guaranteed by the United States

Technology

CFPB Spotlight Targets Mobile ‘Tap-To-Pay’ TechnologyUpdating and Improving the UK Asset Management Regime: An FCA Discussion PaperSEC Issues No-Action Letter Facilitating the Secondary Trading of Digital Assets

Token offering

SEC Clears First Two Regulated Token Offerings

Tokyo Metropolitan Government

The ‘Global Financial City Tokyo’ Initiatives

U.S. Financial Market

Federal Reserve Rate Cut Prompts Demand for Derivative Hedging SolutionsSEC Seeks to Expand ‘Dealer’ or ‘Government Securities Dealer’ Definition to Require Additional Firms to Register with Agency and Comply with Federal Securities RegulationsSEC Proposes Rule Changes to Mutual Fund and Exchange Traded Fund Disclosures

U.S. Supreme Court

Supreme Court Holds That CFPB’s Funding Is Constitutional, Clearing Way for Rulemaking AgendaSupreme Court Hears Oral Argument on Constitutionality of CFPB’s FundingFinancial Services Insights | Spring 2021

UK

Do Non-Bank Financial Institutions Pose a Systemic Risk?Non-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?Non-Bank Lending in the Spotlight: Regulatory Capital and Its Impact

Uncategorized

California Bans Hidden Fees, Effective July 1, 2024Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering ViolationsSEC Passes Long-Awaited New Rule 6c-11 to Modernize Regulation of ETFs

Unclaimed Property & Escheat

Cryptocurrencies and Unclaimed Property: Potential Implications of State Escheat Laws for the Blockchain Technology IndustryUnclaimed Property Litigation Update: Victories on the Horizon for the Holder Community?

Unexplained Wealth Order

Prove It or Lose It! Part III: A Step Too Far? Account Freezing Orders & Account Forfeiture Orders in the UKProve It or Lose It! Parts I and II: Unexplained Wealth Orders and Civil Recovery Orders in the United Kingdom

United Kingdom

Outlook 2026: Financial Services LitigationNon-Bank Lending in the Spotlight – Does the System of Calculating Regulatory Capital Require Revisiting?UK FCA Letter Expresses Concerns About Fund Service Providers

Virtual Currency

Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for BanksSEC Staff Clarifies Stance on Crypto MiningNYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the Greenlist

white collar

CFTC Issues Enforcement Advisory on Benefits of Self-Reporting, Cooperation, and RemediationCTA Countdown: Upcoming FinCEN Filing DeadlinesFinCEN Issues FAQs on Dissolved Entities’ Beneficial Ownership Reporting Requirements

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Greenberg Traurig’s Financial Regulatory and Compliance Group brings together attorneys from various offices and practice areas to assist financial services firms of all types and sizes, as well as vendors to those firms, as they face regulatory, legislative, supervision, examination, licensing, compliance, and governance matters

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