Kelly Truesdale

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Latest Posts › Administrative Procedure Act

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Not Quite Yet: Supreme Court Stays CTA Injunction, But Filing Requirements Remain Suspended

AT A GLANCE - The US Supreme Court has stayed the injunction against the Corporate Transparency Act (CTA), but the requirement for companies to file beneficial ownership information remains suspended, creating ongoing...more

1/27/2025 / Administrative Procedure Act , Appeals , Beneficial Owner , Corporate Transparency Act , Filing Requirements , FinCEN , Preliminary Injunctions , Reporting Requirements , SCOTUS

New Action on No-Action Letters – CFPB Begins Accepting Applications Under Updated No-Action Letter Procedures

The US Consumer Financial Protection Bureau (CFPB) is giving no-action letters (NALs) a second chance. On January 8, 2025, the CFPB issued a policy statement setting forth new procedures for companies to request supervisory...more

1/17/2025 / Administrative Procedure Act , Compliance , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Enforcement Actions , Financial Regulatory Reform , No-Action Letters , Regulatory Requirements

Federal Reserve Wins Two Master Account Lawsuits

At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more

4/11/2024 / Administrative Procedure Act , Banking Sector , Banks , Commodities , Credit Unions , Depository Institutions , Due Process , Federal Reserve , Financial Institutions , FRB

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