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FinCEN Finalizes Rule to Compel Reporting of Individuals and Beneficial Ownership of Entities Involved in Specified Transfers of...

FINCEN’s final rule (RRE Rule), effective December 1, 2025, will require disclosure of the transferor and transferee(s) and the individuals and the beneficial owners of entities involved as transferee in the transfer of...more

FinCEN Extends Beneficial Ownership Reporting Deadline for Companies Created or Registered in 2024

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a rule that extends the deadline from 30 days to 90 days for reporting companies created or registered in 2024 to file initial beneficial...more

Federal Banking Regulators Issue Final Rule Overhauling Community Reinvestment Act Regulations

The expansive final rule overhauls how banks are evaluated for lending to low- and moderate-income customers. The federal banking regulators issued a joint final rule that will govern Community Reinvestment Act (CRA)...more

Implementing the CTA: FinCEN Requires U.S. Companies to Report Beneficial Ownership Information and Protect Against Shell Company...

On September 29, 2022, the U.S. government took an important step in its efforts to increase transparency, combat shell companies, and limit abuse of entities and trusts formed under U.S. state law. The U.S. Treasury...more

Landmark Federal Privacy Bill Clears First Congressional Hurdle

American Data Privacy and Protection Act would require organizations to limit collection of personal information, grant consumers access to their own data, enhance data protections for children, mandate implementation of...more

Federal Banking Regulators Propose Overhaul of Community Reinvestment Act

Regulators took a first step toward modernizing CRA regulations with a joint Notice of Proposed Rulemaking. The proposed rule would add more standardized metrics for regulators’ CRA examinations and more clearly delineate...more

Making Sense of Sanctions Versus SWIFT Delisting

On February 27, 2022, the U.S., UK, and EU announced their agreement that certain Russian banks would be delisted from the Belgian-based Society for Worldwide Interbank Financial Telecommunication (SWIFT). ...more

Senate Confirms Rohit Chopra as CFPB Director

As CFPB Director, Rohit Chopra will vigorously apply the CFPB’s authority to promulgate rules, conduct examinations, and bring enforcement actions. CFPB Acting Director Uejio has laid the groundwork for Director Chopra to...more

Congress Moves to Repeal OCC’s “True Lender” Rule

The Senate has voted to repeal the True Lender Rule using the Congressional Review Act, a measure allowing Congress to disapprove of agency actions and nullify recently adopted administrative rules. The True Lender Rule...more

Virginia’s Consumer Data Protection Act and the Coming Wave of CCPA-like State Privacy Laws

Virginia is the first in 2021 to codify a new data privacy law. The newly signed Virginia Consumer Data Protection Act (CDPA) has parallels to the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy...more

New York Enacts Novel Disclosure Requirements for Commercial Financing Transactions

Fintechs and other nonbanks will be required to provide consumer-style disclosures when offering to extend small business financing in New York. In late December 2020, New York Governor Andrew Cuomo signed into law...more

Trump vs. Biden: Technology and the Internet

In this election cycle, technology and internet policy is a persistent factor across multiple issue areas. With implications for national security, economic equality, infrastructure and market regulation, the next...more

National Banks Allowed to Provide Cryptocurrency Services

OCC grants national banks the authority to provide cryptocurrency custody services for customers. On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter (the letter) granting...more

Banks, Payments and Fintech—Staying Nimble and Customer-Focused during a Pandemic

Recently, Pillsbury’s Deborah Thoren-Peden sat down with a panel of experts that included Millicent Calinog Tracey (former Wells Fargo SVP), Samantha Ettus (founder and CEO of Park Place Payments) and Pillsbury partner John...more

New Privacy Laws in California and New York Are on a Collision Course with the COVID-19 Technology Boom

As COVID-19 fuels technological adoption and adaptation in all walks of life, the CCPA and New York SHIELD Act are front and center in the minds of both government enforcers and the private plaintiffs’ bar. The increased...more

Countdown to CCPA #4: Governor Signs CCPA Amendment to Add Additional Exemptions

Information collected in employment or business-to-business contexts is exempt for one year. For the first year it is in effect, the CCPA will not apply to personal information collected about employees or in B2B...more

New York DFS Creates New FinTech Division

On July 23, 2019, the New York Department of Financial Services announced creation of a Research and Innovation Division to keep pace with FinTech advances. NYDFS Research and Innovation Division created to keep pace with...more

New York Expands Cybersecurity and Data Breach Law

New law in New York State extends requirements on companies doing business with New York residents to have cybersecurity programs and expands New York’s breach notification requirements. New law extends the reach of New...more

Pillsbury’s Post-Election Outlook

The 2018 Midterm Election played out as most poll forecasters speculated. Although several races have yet to be decided, Republicans have retained control of the Senate, but lost at least 29 seats, allowing the Democrats to...more

South Carolina Begins Licensing Money Transmission

South Carolina Anti-Money Laundering Act becomes effective May 25, 2018. Applications must be filed by June 29, 2018. Implementing regulations become effective May 25, 2018. ...more

New FCC Privacy Rules for Broadband and Voice Providers

In an order issued November 2, 2016, the Federal Communications Commission for the first time imposed privacy requirements on providers of broadband internet access services (“BIAS”). The much-anticipated order was an...more

Florida Court: Bitcoin Isn’t “Money”, and Selling It Isn’t “Transmission”

A Florida criminal court has exonerated a defendant charged with violating state money transmission and money laundering laws. In Florida v. Espinoza, the State of Florida charged Michell Abner Espinoza with one count...more

Starting September 1st, Texas Will Require Cash Redemption of Certain Stored Value Cards

Commencing on September 1, 2015, Texas will join several other states in requiring that certain stored value cards be redeemable for cash. Texas House Bill 2391, which becomes effective September 1, 2015, requires cash...more

Texas Renews Efforts to Require Cash Redemption of Certain Stored Value Cards

Texas renews effort to require that certain stored value cards be redeemable for cash if the balance on the card is less than $2.50. In early March, Texas House Bill 2391 was introduced. It would require a cash refund...more

Stay Tuned: Pennsylvania Bill Would Require Cash Refunds on Certain Gift Cards/Certificates

Pennsylvania may be joining the several states that require that certain gift cards and gift certificates be redeemable for cash. Senate Bill 150 would require that a gift card or gift certificate be redeemable for cash when...more

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