Last month, the FDIC proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech partnerships, including some partnerships for programs that do not promise FDIC...more
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more
On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a rule to require reporting of certain US residential real estate transactions (“Final Rule”). The Final Rule...more
I. INTRODUCTION -
On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more
5/31/2024
/ Anti-Money Laundering ,
Compliance ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
NPRM ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
On Tuesday, September 1, 2020, the US Centers for Disease Control and Prevention (the “CDC”) filed a notice of an agency order in the Federal Register titled Temporary Halt in Residential Evictions to Prevent the Further...more
9/8/2020
/ CARES Act ,
Centers for Disease Control and Prevention (CDC) ,
Coronavirus/COVID-19 ,
Eviction ,
Financial Distress ,
Infectious Diseases ,
Landlords ,
Moratorium ,
Public Health ,
Relief Measures ,
Rent ,
Rental Property ,
Tenants