On May 15, 2025, the Division of Trading and Markets (the “Division”) of the U.S. Securities and Exchange Commission (SEC) and the Office of General Counsel of the Financial Industry Regulatory Authority, Inc. (FINRA)...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
On April 4, 2025, the staff of the U.S. Securities and Exchange Commission (SEC or “Commission”) Division of Corporation Finance (“Staff”) issued a statement on stablecoins (the “Stablecoin Statement”), outlining the Staff’s...more
4/9/2025
/ Cryptoassets ,
Digital Assets ,
Enforcement Actions ,
Financial Markets ,
Howey ,
Investment Contract ,
Popular ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stablecoins
On April 1, 2025, the House Financial Services Committee issued a press release regarding a number of Committee requests to various federal agencies for rescission, modification, or re-proposal of specific Biden...more
On March 19, 2025, the staff of the SEC’s Division of Investment Management issued two new FAQs related to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Rule”). The new guidance reduces the complexity of the...more
3/28/2025
/ Asset Management ,
Disclosure Requirements ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Marketing ,
New Guidance ,
Private Funds ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On March 26, 2025, the House Financial Services Committee Subcommittee on Financial Institutions held a hearing, entitled “A New Era for the CFPB: Balancing Power and Reprioritizing Consumer Protections.”...more
On March 14, 2025, a judge in the U.S. District Court for the District of Maryland declined to grant a temporary injunction to the City of Baltimore and the Economic Action Maryland Fund. The plaintiffs had requested an...more
3/21/2025
/ Bank Secrecy Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
Military Lending Act ,
OCC ,
Regulatory Agenda ,
Stablecoins
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments.
This week, we review the following developments as of Wednesday:...more
On February 27, 2025, the staff of the Securities and Exchange Commission’s Division of Corporate Finance (the “staff”) released its views on “meme coins,” stating that under certain circumstances, the offer and sale of “meme...more
On February 20, 2025, House Majority Leader Steve Scalise (R-La.) issued a list of priority regulatory targets for nullification under the CRA “in the coming weeks.” Included on the list is the CFPB’s December 10, 2024 final...more
On February 18, 2025, President Trump signed an Executive Order designed to reduce the power of federal independent agencies by bringing them under the purview of the White House. The Executive Order provides that it applies...more
2/21/2025
/ Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
CRA ,
Executive Orders ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulation Z ,
Regulatory Reform ,
Stablecoins ,
Trump Administration
On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more
2/14/2025
/ CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Enforcement Actions ,
Federal Funding ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OMB ,
Regulatory Agenda
Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
2/7/2025
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Government Efficiency ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration
The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more
2/5/2025
/ CFTC ,
Compliance ,
Enforcement Actions ,
Financial Services Industry ,
Form PF ,
Hedge Funds ,
Investment Adviser ,
Investment Management ,
Private Equity ,
Private Funds ,
Reporting Requirements ,
Rulemaking Process ,
Securities and Exchange Commission (SEC)
Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more
2/3/2025
/ Artificial Intelligence ,
Central Bank Digital Currency (CBDCs) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Financial Regulatory Reform ,
FinTech ,
OMB ,
Regulatory Freeze ,
Secretary of the Treasury ,
Securities and Exchange Commission (SEC) ,
Senate Confirmation Hearings ,
U.S. Treasury
On December 20, 2024, the Securities and Exchange Commission (SEC or the “Commission”) announced charges against several entities that failed to file a Form D within 15 days of a private sale of securities. These entities,...more
1/8/2025
/ Civil Monetary Penalty ,
Compliance ,
Enforcement Actions ,
Filing Deadlines ,
Filing Requirements ,
Form D Filing ,
Investment Adviser ,
Private Equity ,
Private Funds ,
Registration Requirement ,
Regulation D ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
As the end of 2024 approaches, it is crucial that all investment advisers—including registered investment advisers (RIAs) and exempt reporting advisers (ERAs)—complete end of the year regulatory and compliance tasks and...more
On December 5, 2024, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Divisions of Clearing and Risk, Data, Market Oversight, and Market Participants (together, the “Divisions”) issued a staff advisory (the...more
On Thursday, in two separate decisions, a federal district court in Texas struck down the U.S. Securities and Exchange Commission (SEC) rule that expanded the definition of “dealer” to include proprietary traders and some...more
11/22/2024
/ Blockchain ,
Broker-Dealer ,
Cryptocurrency ,
Federal Court Litigation ,
Hedge Funds ,
Investment Management ,
Lack of Authority ,
Securities and Exchange Commission (SEC) ,
Securities Dealers ,
Securities Traders ,
Texas ,
Vacated
On October 21, 2024, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) announced its 2025 Examination Priorities (the “2025 Priorities”), highlighting areas that it expects to target...more
11/4/2024
/ Artificial Intelligence ,
Compliance ,
Cryptocurrency ,
Cybersecurity ,
Investment Adviser ,
Popular ,
Private Funds ,
Registered Investment Advisors ,
Registered Investment Companies (RICs) ,
Regulation S-P ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
The Commodity Futures Trading Commission (CFTC) has adopted amendments to CFTC Rule 4.7, including adjustments to the portfolio requirement financial thresholds in the “qualified eligible person” definition and the...more
Key Takeaways -
•FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly...more
9/26/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Popular ,
Real Estate Transfers ,
Registered Investment Advisors ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury