On April 11, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it will not prioritize enforcement or supervisory actions against nonbank entities that miss upcoming registration deadlines under its Nonbank...more
The Treasury Department announced that it will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing Corporate Transparency Act regulatory deadlines....more
CTA Update - On February 27th, 2025, FinCEN put out a release stating they will not be issuing any fines or penalties or take any other enforcement actions against any companies based on a failure to file beneficial...more
In a press release issued on March 2, 2025, the Treasury Department, which oversees the Financial Crimes and Enforcement Network (FinCEN), announced that it will not enforce any penalties or fines associated with the existing...more
Only a week after announcing a new deadline of March 21, 2025, for filings under the Corporate Transparency Act (CTA), the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it...more
The Corporate Transparency Act (the “CTA”) remains in full force and effect, although FinCEN recently announced that it will not take any enforcement actions against reporting companies who fail either to file or to update...more
In our most recent alert on the Corporate Transparency Act’s (CTA) ever-changing beneficial ownership information (BOI) reporting requirements, we reported that while FinCEN set a new mandatory reporting requirement deadline...more
On February 27, 2025, FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for “those entities...more
In a press release on March 2, 2025, the U.S. Department of the Treasury announced that it will not enforce any penalties or fines associated with the beneficial ownership information (BOI) reporting rule under the existing...more
As we previously announced, last week FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for...more
In a major shift in policy, just days after the Financial Crimes Enforcement Network (“FinCEN”) announced that it would pause enforcement of the beneficial ownership information (“BOI”) reporting requirements under the...more
On March 2, 2025, the United States Department of Treasury announced that it will not enforce fines or penalties based on the existing deadlines for reporting beneficial ownership information under the CTA beneficial...more
On February 27, 2025, the U.S. Financial Crimes Enforcement Network (FinCEN) announced that it intends to issue an interim final rule by March 21, 2025, with extended beneficial ownership information reporting deadlines. It...more
Strap in—Corporate Transparency Act (the “CTA”) compliance has taken yet another unexpected turn. Just as companies were gearing up to meet the March 21st deadline for filing beneficial ownership information (“BOI”) reports...more
In a release dated March 2, 2025, the Treasury Department has indicated that all enforcement of the Corporate Transparency Act (the “CTA”) against United States citizens and domestic reporting companies will be suspended,...more
On February 18, 2025—after a flurry of litigation and uncertainty surrounding the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements—FinCEN set a new mandatory reporting...more
The CTA is not dead, but it is hanging by a thread. On March 2, the U.S. Treasury Department (the Treasury) issued a press release announcing significant updates to the plans announced by FinCEN just a few days earlier....more
The United States Department of Health and Human Services (HHS) has filed court pleadings stating that it does not intend to initiate enforcement actions against plans that maintain copay accumulator programs....more
After we published a post about the Eleventh Circuit’s decision to narrow the scope of the nationwide preliminary injunction of the government contractor vaccine mandate, the government announced that, for the time being, it...more
The Department of Labor (DOL) recently announced that it will not enforce its own rule on investment duties under ERISA. The rule makes it more difficult for investment fiduciaries to consider environmental, social,...more
On March 10, 2021, the U.S. Department of Labor (“DOL”) released an enforcement policy statement indicating that the DOL will not enforce the Trump Administration’s recent amendments to the DOL’s longstanding investment...more
On June 29, 2020, the EPA issued an Addendum to its March 2020 COVID-19 Temporary Enforcement Policy (“Policy”) announcing that the Policy will terminate in its entirety on August 31, 2020. The Addendum also indicates that,...more
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) in response to the continuing threat posed by the coronavirus (COVID-19) pandemic. Among other provisions,...more
The Consumer Financial Protection Bureau (the “CFPB”) released a Policy Statement outlining the responsibilities of credit reporting companies and furnishers during the COVID-19 pandemic. As lenders continue to offer...more
Eight of the ten U.S. states with beverage container redemption programs have temporarily suspended enforcement actions against retailers for failing to accept empty beverage containers for redemption under so-called "bottle...more