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Many US and other non-EU financial institutions which lend or undertake trade finance business on a cross border basis into Europe do so in reliance upon exemptions under local law. These exemptions typically permit these...more
On April 3, 2024, the Department of Labor (DOL) published final changes to Prohibited Transaction Class Exemption 84-14, commonly known as the “QPAM Exemption”. The changes make reliance on the QPAM Exemption more burdensome...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more
Weekly Fintech Focus - • The California DFPI issued new opinions on the scope of its money transmission laws, including the agent of the payee exemption, addressing virtual currency transactions, and pay-in/pay-out...more
In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more
In This Issue. The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert about the scope and content of examinations OCIE plans to conduct of various...more
The U.K. Payment Systems Regulator has opened a consultation on proposals to vary its Specific Direction 10 on Confirmation of Payee. Confirmation of Payee is a system that ensures that certain identifiers (including name,...more
Banks, builders, developers and all those active in commercial real estate, particularly in Maryland, D.C., and Virginia, should be closely following proposed new Treasury Department rules governing foreign investment in real...more
On July 9, 2019, the Board of Governors of the Federal Reserve System (the “FRB”), U.S. Commodity Futures Trading Commission, Federal Deposit Insurance Corporation (the “FDIC”), Office of the Comptroller of the Currency (the...more
In this episode, Jennifer Crowder discusses the State Money Transmitter Licensing (“MTL”) Regime and the impacts of payment innovation. The episode also addresses MTL licensing exemptions, agent and authorized delegates, the...more
We have been following closely efforts by state regulators, state legislatures and the courts to restrict, or in some cases prohibit, bank model lending programs, so the recent guidance from the Vermont Department of...more
The CFPB is proposing significant revisions to its “Policy to Encourage Trial Disclosure Programs” (TDP Policy), which sets forth the Bureau’s standards and procedures for exempting individual companies, on a case-by-case...more
• The Economic Growth, Regulatory Relief and Consumer Protection Act (the Act), which engendered substantial bipartisan support and was recently signed into law by President Donald Trump, amends parts of the Dodd-Frank Wall...more
Current legislative changes in the German Competition Act and the Federal Forest Act bring a set of new antitrust exemptions. We briefly present them in our blog...more
Amendments to Foreign Fund Private Placement Exemptions in the UAE - In August 2016, the Emirates Securities and Commodities Authority (SCA), the federal securities regulator of the United Arab Emirates (UAE), adopted...more
The Federal Communications Commission (FCC) has denied the petition filed by the Mortgage Bankers Association (MBA) seeking an exemption from the prior express consent requirement of the Telephone Consumer Protection Act...more
The CFPB has adopted changes to its Reg Z commentary to memorialize the calculation methods used each year to adjust the thresholds for exempt consumer credit transactions and for transactions exempt from the special...more
The US Board of Governors of the FRS announced the annual indexing of reserve requirement exemption amount and low reserve tranche, two amounts used in determining reserve requirements of depository institutions under...more
U.S. Congressman Jeb Hensarling, Chairman of the House Financial Services Committee, has set the stage for the consideration of regulatory reform and burden reduction with the introduction of H.R. 5983, the “Financial Choice...more
Last month, a bipartisan group of 70 senators were signatories to a letter sent to Consumer Financial Protection Bureau (CFPB) Director Richard Cordray urging the CFPB to “carefully tailor its regulations to match the unique...more
The Consumer Financial Protection Bureau (CFPB) published for comment proposed substantive and organizational changes to the Regulation Z Commentary regarding the calculation of the annual exemption threshold amount for the...more
On August 4, 2016 the CFPB published for comment proposed substantive and organizational changes to the Regulation Z Commentary regarding the calculation of the annual exemption threshold amount for the special appraisal...more
Last week, the Consumer Financial Protection Bureau (CFPB) released its proposed amendments to the “Know Before You Owe” mortgage disclosure rule, commonly known as the Truth in Lending Act-Real Estate Settlement Procedures...more
The CFPB and Federal Reserve Board have proposed amendments to their official Regulations Z and M staff commentaries to memorialize the calculation method used by the agencies each year to adjust the thresholds for exempt...more
On May 11, 2016, FinCEN published in the Federal Register its long-awaited anti-money laundering (“AML”) rules (the “Final Rules”) governing corporate entities doing business with banks and other financial institutions that...more