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An Offer You Can’t Refuse: The FTC’s New “Click-to-Cancel” Rule

On January 14, 2025, the first part of the Federal Trade Commission’s (“FTC”) update to the Negative Option Rule went into effect. Negative options are contract terms that allow a seller to interpret a customer’s silence or...more

California Bill Aims to Expand Debt Collection Protections to Commercial Debts

On September 24, 2024, Governor Gavin Newsom signed into law California Senate Bill 1286 (“SB 1286”). SB 1286 will extend existing consumer debt collection protections in California to small businesses and to the collection...more

FinCEN Issues Proposed Rule to Enhance Financial Institutions’ AML/CFT Programs

On June 28, 2024, in an effort to bolster financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs, the U.S. Department of the Treasury’s Financial Crimes Enforcement...more

Update: OCC Issues Notice of Proposed Rulemaking on Business Combinations

The Office of the Comptroller of the Currency (“OCC”) recently sought comment on a proposed rule designed to increase the transparency of the standards applicable to the OCC’s review of business combinations (i.e., bank...more

FDIC Releases Proposed Updates to Statement of Policy on Bank Merger Transactions

The Federal Deposit Insurance Corporation (“FDIC”) recently published a Federal Register notice seeking public comment on proposed revisions to the FDIC’s Statement of Policy on Bank Merger Transactions (the “SOP”). Relevant...more

OCC Issues Notice of Proposed Rulemaking on Business Combinations

The Office of the Comptroller of the Currency (“OCC”) recently sought comment on a proposed rule designed to increase the transparency of the standards applicable to the OCC’s review of business combinations (i.e., bank...more

Proposed CFPB Rule Could Subject “Big Tech” Companies to Enhanced Regulatory Scrutiny

On November 7, 2023, the Consumer Financial Protection Bureau (“CFPB”) proposed a rule that would allow the CFPB to supervise certain large nonbank companies that provide consumer financial services such as digital wallets...more

Final Rule Updating the Community Reinvestment Act Issued by Bank Regulators

On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “Agencies”) issued a final rule designed to...more

Federal Regulators Issue Updated Guidance on Liquidity Risks and Contingency Planning

On July 28, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the National Credit Union Administration (the “NCUA”) and the Office of the...more

Federal Regulators Issue Notice of Proposed Rulemaking Revising Capital Requirements for Large Banks and Banks with Significant...

On July 27, 2023, in an effort to bolster the resilience of the U.S. banking system in the aftermath of recent bank failures and to promote consistency with international banking capital standards, the Federal Deposit...more

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