On May 1, the Consumer Financial Protection Bureau (CFPB) announced that it will not prioritize enforcement or supervision of its small business lending data collection rule (the “Rule”) implementing the requirements of...more
On April 8, 2025, then Acting Chairman Mark T. Uyeda of the U.S. Securities and Exchange Commission (“SEC”), highlighted in remarks before the Annual Conference on Federal and State Securities Cooperation two areas where...more
4/22/2025
/ Broker-Dealer ,
Investment ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
NSMIA ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
SIFMA ,
State Securities Regulators
The Financial Crimes and Enforcement Network of the U.S. Treasury Department (FinCEN) on March 21, 2025 announced an interim final rule (the “Interim Rule”) which, if finalized in its current form, exempts all domestic...more
The last remaining nationwide injunction pausing obligatory reporting under the Corporate Transparency Act (CTA) and the related regulations (31 C.F.R. § 1010.380) was lifted on February 17, 2025. Absent further...more
Following up on our most recent blog post on developments regarding the enforcement date for the Corporate transparency Act (“CTA”), on December 26, 2024, the Fifth Circuit Panel that will ultimately be handling the merits of...more
12/30/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
Following up on our most recent blog post on developments regarding the enforcement date for the CTA, on the afternoon of December 23, 2024, the Fifth Circuit issued its order staying the U.S. District Court for the Eastern...more
12/24/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
Updated December 10, 2024 to reflect the U.S. Government has filed a notice to appeal the lower court's injunction.
On December 3, the U.S. District Court for the Eastern District of Texas (“Court”) entered a sweeping...more
With the amount of commercial real estate loans scheduled for maturity over the next several years expected to increase significantly, there is accompanying heightened risk that some borrowers may be unable to replace their...more
11/7/2024
/ Banking Sector ,
Banks ,
Borrowers ,
Commercial Loans ,
Commercial Real Estate Market ,
Lenders ,
Loans ,
New Guidance ,
OCC ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management
On June 6, 2023, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and collectively with the...more
In the fourteen years since the 2008 financial crisis, significant actions have been taken by Federal banking agencies to make the largest financial institutions more resilient and less likely to fail and to require planning...more