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Cadwalader, Wickersham & Taft LLP

FFFrictions, August 2025 - FinCEN Restrictions on Certain Mexican Banks

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New and significant prohibitions against financial transactions between U.S. financial institutions and three Mexican financial institutions are set to go into effect in a little over a month on September 4, 2025. In late...more

Seyfarth Shaw LLP

The Corporate Transparency Act: Considerations for Special Purpose Entities in Commercial Real Estate Transactions

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Corporate structures in commercial real estate transactions can often be very complex and involve layers of entities. Special purpose entities that are bankruptcy remote (“SPEs”) are frequently used in commercial real estate...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Goodwin

House Votes to Repeal OCC True Lender Rule

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In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

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In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Goodwin

Federal Reserve Proposes Rules To Modernize Regulations That Implement CRA

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In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more

Ballard Spahr LLP

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

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Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

White and Williams LLP

The Main Street Business Lending Program – Updated Frequently Asked Questions

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On May 27, 2020, the Federal Reserve Bank of Boston (FRBB) released a significantly updated set of “Frequently Asked Questions” (Updated FAQs), offering additional insight into the details of the Main Street Business Lending...more

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