News & Analysis as of

Third-Party Regulatory Reform

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

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In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

Husch Blackwell LLP on

By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Paul Hastings LLP

SEC Withdraws 14 Pending Rule Proposals

Paul Hastings LLP on

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

Epstein Becker & Green

Georgia Regulates Third Party Litigation Financing in Senate Bill 69

On February 27, 2025, by a vote of 52 to 0, the Georgia Senate passed Senate Bill 69, titled “Georgia Courts Access and Consumer Protection Act.”...more

American Conference Institute (ACI)

The Big Picture: Anti-Corruption Enforcement and Integrity Program Developments in Brazil

The last several months brought forth major reforms to Brazil’s anti-corruption regulations and enforcement environment, including in the way that Brazilian companies are expected to enhance their compliance programs....more

K&L Gates LLP

Third-Party Litigation Funding in England and Wales Post-PACCAR: Where Are We Now?

K&L Gates LLP on

In our earlier alert on third-party funding (TPF) and the UK Supreme Court’s decision in PACCAR, we discussed the initial industry reaction, subsequent litigation, and legislative reform proposals (at the time, through the...more

Ankura

Balancing Agility and Speed with Preparation and Stability: Importance of Governance in a Fintech Startup

Ankura on

In all our work with clients, my evaluation and expectations around compliance readiness come down to one point: Governance. This can mean a variety of things when it comes to a compliance program, but overall, we boil it...more

Jones Day

SEC Reopens Comment Period for Rule Proposing New Disclosures for Security-Based Swaps

Jones Day on

The Situation: The Securities and Exchange Commission ("SEC") has reopened the comment period for its proposed rule requiring public disclosure of security-based swap ("SBS") positions that exceed certain thresholds....more

Kohrman Jackson & Krantz LLP

Ohio Passes Version of The INFORM Consumers Act

Ohio has taken a step to protect brands that are dealing with unauthorized, counterfeit and gray market sales from online marketplaces. Governor Mike DeWine recently signed the bipartisan Ohio House Bill 272 (H.B. 272) into...more

Jones Day

DOJ Announces Merger Process Reforms: Déjà Vu All Over Again?

Jones Day on

The Situation: Between 2013 and 2017, the average length of a U.S. Department of Justice ("DOJ") Antitrust Division merger review increased 65 percent to 10.8 months. The Response: DOJ announced reforms to improve...more

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