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Rulemaking Process Disclosure Requirements Financial Services Industry

Ballard Spahr LLP

CFPB will not issue revised BNPL rule

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Having previously announced that it was withdrawing its Buy Now, Pay Later rule, the CFPB recently said that it does not intend to issue a revised rule....more

Paul Hastings LLP

SEC Withdraws 14 Pending Rule Proposals

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On June 12, the Securities and Exchange Commission (SEC) formally withdrew 14 proposed rules for investment advisers, broker-dealers and public companies, many of which had been pending for several years. Should the SEC...more

Allen Matkins

Ninth Circuit Upholds DFPI's Commercial Financing Disclosure Rules

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On September 30, 2018, California enacted SB 1235, codified at California Financial Codes sections 22800–22805. SB 1235 requires that an offer of commercial financing for $500,000 or less be accompanied by disclosures of: (1)...more

Davis Wright Tremaine LLP

Writing on a New SLATE – DWT's FINRA Expertise

The SEC's Rule 10c-1a now mandates the reporting of securities loans, marking a significant regulatory shift. Potential challenges in implementing SLATE, including the need for possible adjustments to data dissemination...more

Carlton Fields

Getting Clued In: How the SEC’s RILA Rulemaking Affects Variable Annuities

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The recent rule and form amendments adopted by the SEC to facilitate the registration of registered index-linked annuities (RILAs) and market-value adjustment annuities (MVAs) on Form N-4 have been broadly welcomed by the...more

Carlton Fields

Amendments to N-PORT May Be OUT-Ported New SEC Reporting Requirements Already Under Challenge

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Gary Gensler’s tenure as SEC chair can be remembered for an impressive number of rule proposals, many of which encountered vehement industry opposition or were challenged in court, struck down, or stayed....more

WilmerHale

SEC Approves FINRA Rules to Establish Securities Lending Reporting Facility

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On January 2, 2025, the Securities and Exchange Commission (SEC) approved the FINRA Rule 6500 Series (the SLATE Rules), which establishes the Securities Lending and Transparency Engine (SLATE), a new facility for the...more

Sheppard Mullin Richter & Hampton LLP

Texas Passes Law Expanding Mortgage Borrower Protections

Effective November 23, 2024, the Texas Department of Savings and Mortgage Lending (the “DSML”) adopted new rules affecting mortgage loan companies, mortgage bankers, individual residential mortgage loan originators, and...more

Ballard Spahr LLP

FTC issues Fall 2023 rulemaking agenda

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The Federal Trade Commission has released its Fall 2023 rulemaking agenda as part of the Fall 2023 Unified Agenda of Federal Regulatory and Deregulatory Actions....more

Ballard Spahr LLP

AFSA asks House Appropriations Committee to block proposed FTC Motor Vehicle Dealers Trade Regulation Rule

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On June 21, 2023, the American Financial Services Association (“AFSA”) asked the House Appropriations Committee to include language in the Financial Services and General Government appropriations bill that would prevent the...more

Sheppard Mullin Richter & Hampton LLP

Consumer Fees Find Themselves in the Crosshairs: The CFPB Seeks Public Input on Alleged “Junk Fees” in the Consumer Financial...

The Consumer Financial Protection Bureau (“CFPB”) has continued to ratchet up its regulatory scrutiny over the consumer financial services market. On January 26, 2022, the CFPB published an initiative seeking public input on...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

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In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Sheppard Mullin Richter & Hampton LLP

More Regulatory Clarity on the Horizon for FinTech

On September 21, 2021, the FinTech task force of the U.S. House Committee on Financial Services held a hearing on consumer privacy. The hearing was live-streamed and the archived webcast is available on the Committee website....more

Ballard Spahr LLP

CFPB issues proposed rule to require debt collectors to make disclosures for time-barred debts

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The CFPB has issued a proposal that would require debt collectors to make specified disclosures when collecting time-barred debts (Disclosure Proposal).  The Disclosure Proposal supplements the Bureau’s proposed debt...more

Ballard Spahr LLP

Georgia and Colorado Address MLO Temporary Authority to Operate

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Following receipt and consideration of three written comments on proposed rules distributed on November 18, 2019, the Georgia Department of Banking and Finance adopted final rules on December 20, 2019, that establish...more

Ballard Spahr LLP

CFPB to Assess TRID Rule’s Effectiveness

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The Dodd-Frank Act requires the CFPB to conduct an assessment of each “significant rule” adopted by the Bureau. The Bureau has determined that the TILA/RESPA Integrated Disclosure (TRID) Rule qualifies as a “significant...more

Ballard Spahr LLP

Prepaid account agreements database now on CFPB website

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The CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends,...more

Ballard Spahr LLP

CFPB Updates TRID Rule FAQs to Address Providing a Loan Estimate to Consumers

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The CFPB recently updated the TRID rule FAQs to address questions about providing a Loan Estimate to consumers. The FAQs mostly confirm guidance previously provided by the CFPB in various forms. ...more

Cadwalader, Wickersham & Taft LLP

SEC Adopts Regulation Best Interest

The Securities and Exchange Commission (the “SEC”) on June 5 adopted Regulation Best Interest: The Broker-Dealer Standard of Conduct (“Reg BI”), which requires that broker-dealers act in the “best interest” of their “retail...more

Mayer Brown Free Writings + Perspectives

Disclosure Effectiveness Testing Act

The House Financial Services Committee recently passed H.R. 1815, which is the Securities and Exchange Commission Disclosure Effectiveness Testing Act. ...more

Ballard Spahr LLP

CFPB clarifies coverage of “disclosure sandbox” proposal; consumer groups comment on proposed revisions to no-action letter policy...

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“Disclosure Sandbox.”  In September 2018, the Bureau proposed significant revisions to its “Policy to Encourage Trial Disclosure Programs” which sets forth the Bureau’s standards and procedures for exempting individual...more

Ballard Spahr LLP

April 1 effective date of prepaid rule leaves little remaining time for addressing significant compliance challenges

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After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019. ...more

Ballard Spahr LLP

CA regulator invites comments on proposed rulemaking to implement new law requiring commercial financing disclosures

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The California Department of Business Oversight (DBO) has issued an invitation for comments from stakeholders in developing regulations to implement SB 1235, the bill signed into law on September 30, 2018 that requires...more

Mayer Brown Free Writings + Perspectives

Insights Regarding Areas of Focus for Division of Corporation Finance

Speaking at a session at the American Bar Association’s annual meeting, a representative of the Securities and Exchange Commission’s Division of Corporation Finance (Michael Seaman) provided guidance for attendees regarding...more

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