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Enforcement Actions › Administrative Procedure Act › Regulatory Oversight

Ballard Spahr LLP

CFPB won’t prioritize BNPL enforcement

Ballard Spahr LLP on

The CFPB will not make enforcement of its Buy Now, Pay Later rule a priority, according to a recent statement....more

Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - CFTC Staff Withdraws Advisory on Swap Execution Facility Registration Requirement

Cadwalader, Wickersham & Taft LLP on

On March 13, 2025, the Commodities Futures Trading Commission (“CFTC”) issued Letter 25-05, withdrawing controversial and much-criticized Staff Letter 21-19 (“SEF Registration Advisory”), which was issued September 29, 2021...more

Nelson Mullins Riley & Scarborough LLP

No Soup for You - SEC Commissioners Revoke Authority of Director of Enforcement to Launch Investigations

Nelson Mullins Riley & Scarborough LLP on

In a famous Seinfeld episode, a master soup maker had strict rules for ordering his delicious confections.  A violation of his rules, resulted in “No soup for you!”...more

Orrick, Herrington & Sutcliffe LLP

Baltimore government files to challenge the CFPB’s funding decisions, Vought delays budget cuts

Orrick, Herrington & Sutcliffe LLP on

On February 12, a complaint was filed in the U.S. District Court for the District of Maryland against the CFPB and its Acting Director, Russell Vought. The plaintiffs — which include the Mayor and City Council of Baltimore,...more

Carlton Fields

Piecing Alpine Together

Carlton Fields on

Is FINRA constitutional? According to the D.C. Circuit’s November 2024 opinion in Alpine Securities Corp. v. FINRA, FINRA proceedings may be unconstitutional in one narrow set of circumstances. ...more

Mintz - Health Care Viewpoints

EnforceMintz — Medicare Advantage and Part D Programs to Remain in the Enforcement Spotlight in 2025

Mintz - Health Care Viewpoints on

As government scrutiny and enforcement targeting the Medicare Advantage (Medicare Part C) program continued in 2024, the industry’s response to agency actions escalated. Last year also resulted in the first sizable Part D...more

Carlton Fields

Fifth Circuit Breaks From No-Action Pack: Becomes Better Bet for Letter Recipients?

Carlton Fields on

On July 21, 2023, a three-judge panel of the Fifth Circuit Court of Appeals issued an opinion asserting that the Commodity Futures Trading Commission’s Division of Market Oversight likely acted arbitrarily and capriciously,...more

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