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Enforcement Actions Registration Requirement

Hudson Cook, LLP

CFPB Enforcement Order Registry Requirements Effective September 16

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Who's Covered: Registrations and Written Statements - Generally, a covered nonbank with a covered order in effect on or after September 16, 2024, must register and submit information to the CFPB about the entity and the...more

Latham & Watkins LLP

CFPB Creates Corporate Nonbank Enforcement Registry

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The centralized repository would assist the CFPB and law enforcement in detecting patterns of misbehavior and recidivism adversely affecting consumers. On June 3, 2024, the Consumer Financial Protection Bureau (CFPB)...more

Venable LLP

CFPB to Launch Registry of Nonbank Enforcement Actions

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In a move that's sure to make nonbank financial institutions even more uncomfortable, the Consumer Financial Protection Bureau (CFPB) has decided to shine a brighter light on those that have been alleged to violate consumer...more

Hudson Cook, LLP

CFPB Non-Bank Enforcement Order Registry Coming this Fall

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Constitutionality concerns cleared, the Consumer Financial Protection Bureau (CFPB) on June 3 issued its final rule creating a registry identifying covered nonbanks subject to government agency enforcement orders. The rule's...more

Troutman Pepper

CFPB Issues Final Rule on Nonbank Registration of Enforcement Orders

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On June 3, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rule requiring covered nonbanks to register enforcement orders, and it is a doozy. Not only will covered nonbanks be required to register...more

American Conference Institute (ACI)

[Event] 5th National Forum on FARA - December 1st, National Harbor, MD

Hosted by American Conference Institute, the 5th National Forum on FARA returns for another exciting year with curated programming that will feature the most complex, high stakes FARA issues at the forefront. This event is...more

Troutman Pepper

Utah State Court Rejects Claim Based on Debt Collector’s Alleged Failure to Register Under Collection Agency Act

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The Utah court of appeals has recently affirmed the dismissal of a plaintiff’s suit against a debt buyer based on its alleged failure to register as a collection agency prior to filing collection lawsuits. The court’s...more

Sheppard Mullin Richter & Hampton LLP

The SEC’s Sudden Impact on NFTs!

On August 28, 2023, the Securities and Exchange Commission (“SEC”) instituted cease-and-desist proceedings under Section 8A of the Securities Act against Impact Theory, a Los Angeles media and entertainment company, alleging...more

Jenner & Block

Client Alert: Court Adopts SEC's New Unregistered Dealer Theory, Creates Risk of Disgorgement and Penalties for Anyone Trading...

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A broad array of financial market participants—mutual funds, private funds, insurers, pension funds, family offices, individuals, and more—may be at risk after the Securities and Exchange Commission (SEC) secured summary...more

Holland & Knight LLP

Prefabricated Facts: SEC Charges "Queen of Mobile Homes," Others for Years-Long Scheme

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A recent enforcement action from the Fort Worth Regional Office of the SEC reminds one of the agency's investor-protection mission and continued focus on those who deceive retail investors in the private offer and sale of...more

Braumiller Law Group, PLLC

[Webinar] ITAR 101 - Part 2 - June 27th, 10:30 am - 11:30 am CST

Join Braumiller Law Group Senior Counsel Bruce Leeds for a discussion on the topic of: ITAR 101-Part 2* New to the International Traffic in Arms Regulations (ITAR)? Or, maybe you're just a little bit rusty on the ITAR? Here...more

BCLP

A Time of Transition for the CFTC

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Over the past year, the Commodity Futures Trading Commission continued moving its focus away from practices like spoofing, instead bringing high-profile actions in the crypto space and reaching significant settlements with...more

Wiley Rein LLP

FARA: 2022 Review and 2023 Preview

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The trend in aggressive enforcement of the Foreign Agents Registration Act (FARA) enforcement continued in 2022 with the Department of Justice’s (DOJ) first affirmative civil enforcement lawsuit in over 20 years and a number...more

Goodwin

CFPB Proposes Rule That Nonbanks Subject to Certain Public Orders Must Publicly Register with CFPB As a Means of Detecting “Repeat...

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On December 12, 2022, the Consumer Financial Protection Bureau (“CFPB”) proposed a rule (“Proposed Rule”) that would require non-bank financial institutions to register with the CFPB when they become subject to certain final...more

Cadwalader, Wickersham & Taft LLP

CFTC Sanctions Registered CTA for Operating Unregistered SEF

On September 26, the Commodity Futures Trading Commission (“CFTC”) published an order settling charges against Asset Risk Management, LLC (“ARM”), a registered commodity trading advisor (“CTA”) headquartered in Houston,...more

Goodwin

CFTC Attempts to Extend Liability to DAO Participants

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In a first of its kind enforcement action, the Commodity Futures Trading Commission (“CFTC”) is attempting to hold participating members of a decentralized autonomous organization (“DAO”) liable for alleged violations of the...more

Goodwin

SEC Sanctions Broker for Failure to Register as Municipal Advisor and for Inadequate Procedures to Ensure Registration: A Reminder...

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​​​​​​​On September 14, 2022, the SEC announced a settled administrative order, also dated September 14 (“Order”), imposing penalties, including a $100,000 fine, on a registered broker (the “Broker”) for failing to (1)...more

Vinson & Elkins LLP

FARA Enforcement Is Here to Stay

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On June 7, 2022, the media published a search warrant application seeking access to the electronic communications of a retired four-star Marine Corps general, General John R. Allen, in a criminal investigation into potential...more

Goodwin

District Court Denies Payday Lender's Bid To Dismiss SEC Enforcement Action

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District Court Denies Payday Lender's Bid To Dismiss SEC Enforcement Action; Delaware Chancery Court Dismisses Camping World Insider Trading Derivative Suit; California Federal Judge Certifies Class Of Apple Common-Stock...more

Pillsbury - Internet & Social Media Law Blog

First-of-Its-Kind Settlement Brings Clarity for Players in Retail Crypto Market

On February 14, the Securities and Exchange Commission (SEC) announced that it had entered into a settlement with BlockFi Lending LLC, a subsidiary of BlockFi Inc., (collectively BlockFi) over first-of-its-kind charges that...more

Proskauer - Blockchain and the Law

CFTC Issues Cease and Desist Order to Binary Options Operator Using Smart Contracts

On January 3, 2022, the Commodity Futures Trading Commission (the “CFTC”) entered an order charging Blockratize, Inc. (d/b/a Polymarket.com) (“Polymarket”) with offering off-exchange binary options contracts and failing to...more

Wiley Rein LLP

FARA 2021 Year in Review

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The Foreign Agents Registration Act (FARA) continued to make headlines in 2021 as enforcement and modernization of the law remained a U.S. Department of Justice (DOJ) priority. DOJ maintained its focus on enforcement,...more

Proskauer - Corporate Defense and Disputes

Disgorgement Continues at the SEC

On October 12, 2021, the Fifth Circuit Court of Appeals upheld a disgorgement order issued by the SEC, in—according to the opinion— the first appellate ruling on the topic since the Supreme Court’s 2020 decision in Liu v....more

Conn Kavanaugh

Failure to Register With FINRA as a Broker-Dealer Can Cost Mergers and Acquisitions Brokers Dearly

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Conn Kavanaugh attorneys Andrew R. Dennington and Julie M. Muller recently secured a significant win for their client before the U.S. First Circuit Court of Appeals. The First Circuit affirmed that summary judgment properly...more

JAMS

The SEC’s Proposed Exemptive Order for Finders in Private Placements: An Uncertain Future for Regulatory Certainty - Perspectives...

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At age 79, Paul Anka, the crooner and songwriter, is more relevant than ever. In 2020, he appeared on Season 4 of “The Masked Singer,” enjoyed a popular resurgence courtesy of TikTok, reworked his anthem “My Way” for the...more

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