On July 23, several plaintiffs filed a complaint against the CFPB in the U.S. District Court for the District of Columbia alleging the CFPB and its acting director violated federal law by delaying implementation and...more
Earlier this month, the US Senate voted 99-1 to strike a key clause in a sweeping Republican domestic policy bill that sought to impose a ten-year moratorium on states’ enforcement of artificial intelligence regulations. Had...more
On January 17, 2025, the ERISA Industry Committee (“ERIC”) filed suit in the U.S. Court of Appeals for the D.C. Circuit asking the court to hold various key provisions under the 2024 Mental Health Parity Addiction Equity Act...more
The executive order shifts policy on enforcement of criminal regulatory offenses, steering away from criminal enforcement of strict liability offenses in regulatory matters....more
Last week, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) issued a nonenforcement policy regarding the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) final regulations,...more
Federal regulators recently indicated they will not enforce parts of the final regulations issued in September 2024 under the Mental Health Parity and Addiction Equity Act (MHPAEA) and may soon propose new rules altogether....more
In connection with its regulation titled "Small Business Lending Under the Equal Credit Opportunity Act (Regulation B)," implementing Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, 88 Fed. Reg....more
On April 11, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it will not prioritize enforcement or supervisory actions against nonbank entities that miss upcoming registration deadlines under its Nonbank...more
The Treasury Department announced that it will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing Corporate Transparency Act regulatory deadlines....more
CTA Update - On February 27th, 2025, FinCEN put out a release stating they will not be issuing any fines or penalties or take any other enforcement actions against any companies based on a failure to file beneficial...more
In a press release issued on March 2, 2025, the Treasury Department, which oversees the Financial Crimes and Enforcement Network (FinCEN), announced that it will not enforce any penalties or fines associated with the existing...more
Only a week after announcing a new deadline of March 21, 2025, for filings under the Corporate Transparency Act (CTA), the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it...more
The Corporate Transparency Act (the “CTA”) remains in full force and effect, although FinCEN recently announced that it will not take any enforcement actions against reporting companies who fail either to file or to update...more
In our most recent alert on the Corporate Transparency Act’s (CTA) ever-changing beneficial ownership information (BOI) reporting requirements, we reported that while FinCEN set a new mandatory reporting requirement deadline...more
On February 27, 2025, FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for “those entities...more
In a press release on March 2, 2025, the U.S. Department of the Treasury announced that it will not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more
As we previously announced, last week FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for...more
In a major shift in policy, just days after the Financial Crimes Enforcement Network (“FinCEN”) announced that it would pause enforcement of the beneficial ownership information (“BOI”) reporting requirements under the...more
On March 2, 2025, the United States Department of Treasury announced that it will not enforce fines or penalties based on the existing deadlines for reporting beneficial ownership information under the CTA beneficial...more
On February 27, 2025, the U.S. Financial Crimes Enforcement Network (FinCEN) announced that it intends to issue an interim final rule by March 21, 2025, with extended beneficial ownership information reporting deadlines. It...more
Strap in—Corporate Transparency Act (the “CTA”) compliance has taken yet another unexpected turn. Just as companies were gearing up to meet the March 21st deadline for filing beneficial ownership information (“BOI”) reports...more
In a release dated March 2, 2025, the Treasury Department has indicated that all enforcement of the Corporate Transparency Act (the “CTA”) against United States citizens and domestic reporting companies will be suspended,...more
On February 18, 2025—after a flurry of litigation and uncertainty surrounding the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements—FinCEN set a new mandatory reporting...more
The CTA is not dead, but it is hanging by a thread. On March 2, the U.S. Treasury Department (the Treasury) issued a press release announcing significant updates to the plans announced by FinCEN just a few days earlier....more
The United States Department of Health and Human Services (HHS) has filed court pleadings stating that it does not intend to initiate enforcement actions against plans that maintain copay accumulator programs....more