The NYS LLC Transparency Act (the “New York Act”) became law in January 2024 and takes effect on January 1, 2026. When in effect, it would require limited liability companies formed or qualified to do business in New York to...more
5/7/2025
/ Beneficial Owner ,
Business Ownership ,
Corporate Transparency Act ,
Disclosure Requirements ,
Filing Requirements ,
FinCEN ,
Interim Final Rules (IFR) ,
Limited Liability Company (LLC) ,
New Regulations ,
New York ,
Regulatory Requirements ,
Reporting Requirements
On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more
3/20/2025
/ Anti-Money Laundering ,
Compliance ,
Federal Register ,
Financial Services Industry ,
FinCEN ,
Geographic Targeting Order ,
Money Services Business ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Suspicious Activity Reports (SARs)
President Trump campaigned on the promise to make the United States the “crypto capital” of the world. In his first days in office, he took steps to advance that goal, including by signing an executive order designed to...more
2/10/2025
/ Bitcoin ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
FDIC ,
Federal Reserve ,
FinTech ,
Popular ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
The saga of the CTA continues. Adopted in January 2021, the Corporate Transparency Act (CTA) is intended to assist in identifying beneficial ownership and control of entities operating in the United States in order to...more
1/28/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Business Entities ,
Constitutional Challenges ,
Corporate Counsel ,
Corporate Transparency Act ,
Enforcement ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
SCOTUS
The Fifth Circuit Court of Appeals has stayed the preliminary injunction issued on December 3, 2024, in the Texas Top Cop Shop case by a U.S. District Court. As a result, the original beneficial ownership reporting...more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
On November 1, 2024, the next phase of several significant amendments to the New York Department of Financial Services’ (NYDFS) cybersecurity regulation take effect. These specific amendments, enacted in 2023, impact the...more
Beneficial Ownership Reports are filed electronically through the Financial Crimes Enforcement Network.
Individuals who need to be reported as beneficial owners or company applicants should apply for a FinCEN ID number....more
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
9/10/2024
/ Bank Secrecy Act ,
Beneficial Owner ,
Corporate Transparency Act ,
Disclosure Requirements ,
Exemptions ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Real Estate Transfers ,
Reporting Requirements ,
Residential Real Estate Market
On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential...more
On March 12, 2024, Acting Comptroller of the Currency Michael Hsu indicated in a speech that regulations may soon be forthcoming that would be designed to bolster larger depository institutions’ ability to withstand...more
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
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
Recent actions by the Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB), with support from the Biden administration, signal that protecting consumers from so-called “junk fees” remains a key...more
10/23/2023
/ Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Excessive Fees ,
Federal Trade Commission (FTC) ,
Fees ,
Hidden Fees ,
Misleading Statements ,
Notice of Proposed Rulemaking (NOPR) ,
Overdraft Fees ,
Price Inflation ,
Unfair or Deceptive Trade Practices
The Federal Deposit Insurance Corporation (FDIC) recently published a consent order issued against Cross River Bank that alleged the bank’s fair lending program’s noncompliance and weaknesses in its oversight of fintech...more
6/21/2023
/ Banking Regulators ,
Banks ,
Compliance ,
Consent ,
Due Diligence ,
Enforcement ,
Fair Lending ,
FDIC ,
FinTech ,
Notice of Non-Compliance ,
OCC ,
Partnerships ,
Risk Assessment
On May 23, the White House revealed three new steps advancing the research, development and deployment of AI technology nationwide.
The Biden Administration has updated the National Artificial Intelligence R&D Plan for...more
6/7/2023
/ Artificial Intelligence ,
Biden Administration ,
Department of Health and Human Services (HHS) ,
Ethics ,
Investment ,
Machine Learning ,
NIST ,
OMB ,
OSTP ,
Research and Development ,
Risk Assessment
Four U.S. agencies (the Consumer Financial Protection Bureau, Department of Justice, Equal Employment Opportunity Commission and Federal Trade Commission) have issued a joint statement to establish a renewed, coordinated...more
5/10/2023
A far-reaching new federal regulation will for the first time require small business lenders to collect detailed data about applications and originations, and report that data to the Consumer Financial Protection Bureau...more
On February 8, 2023, the U.S. Department of the Treasury released a report citing its “findings on the current state of cloud adoption in the sector, including potential benefits and challenges associated with increased...more
New York has joined California and several other states in finalizing regulations requiring consumer-style disclosures for broad categories of commercial financing transactions....more
The Consumer Financial Protection Bureau (CFPB), the primary federal regulator charged with enforcing consumer financial protection laws, recently announced a proposed rulemaking that would require the myriad non-banks...more
In 2023, the NYDFS is poised to finalize several significant new regulations and will likely continue its aggressive cybersecurity, anti-money laundering (AML) and consumer protection enforcement.
The New York Department of...more
As of December 9, 2022, California is requiring consumer-style disclosures for broad categories of commercial financing transactions, continuing the trend toward increased scrutiny of commercial lending.
On June 9, 2022,...more
Lenders will soon be required to collect detailed demographic and financial data on commercial credit applicants and report this data to regulators.
The NYDFS issued a proposed rule that will require New York banks to...more
11/11/2022
/ Commercial Loans ,
Community Reinvestment Act ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Applicants ,
Dodd-Frank ,
ECOA ,
FDIC ,
HMDA ,
Notice of Proposed Rulemaking (NOPR) ,
NYDFS ,
Proposed Rules ,
Small Business Loans
NYDFS is closely evaluating fair lending compliance at the institutions it regulates, and bringing enforcement actions based on statistical analyses of lenders’ loan portfolios.
NYDFS has entered into a series of consent...more
10/19/2022
/ Compliance ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Fair Lending ,
Financial Regulatory Agencies ,
Interest Rates ,
Lenders ,
NYDFS ,
Penalties ,
Protected Class ,
State Banks
The trend toward increased regulation of commercial lending continues with California’s approval of regulations requiring consumer-style disclosures for broad categories of commercial financing transactions.
On June 9,...more