On March 1, 2024, New York State Governor Kathy Hochul signed into law a revised version of New York State's LLC Transparency Act, which is modeled on FinCEN's Beneficial Ownership Information Rule. Other states are...more
The Financial Crimes Enforcement Network ("FinCEN") has issued a final rule ("Final Rule") extending the initial reporting deadline for new entities required to file beneficial ownership information ("BOI") with FinCEN to 90...more
In Short:
The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more
10/19/2023
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FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Lenders ,
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Proposed Rules ,
Subsidiaries
In Short -
The Situation: The Federal Deposit Insurance Corporation ("FDIC") has proposed significant amendments (the "Proposal") to its rule requiring covered insured depository institutions ("CIDIs") to prepare and file...more
An estimated 32.6 million domestic and foreign companies will soon be required to report information about their beneficial owners to the U.S. Treasury. This White Paper describes the new requirements and the steps companies...more
The Massachusetts Student Loan Borrower Bill of Rights The SL Bill of Rights came into effect on July 1, 2021, and the DOB issued its implementing regulations on the same day. Building upon and codifying earlier proposed...more
On July 15, 2021, a three-judge panel of the U.S. Court of Appeals for the Second Circuit held in Homaidan v. Sallie Mae, Inc., et al. that the private student loans at issue were not subject to the discharge exemption in...more
The Situation: The New York Department of Financial Services ("NYDFS") has established a Statewide Office of Financial Inclusion and Empowerment, providing yet another example of state and federal regulators prioritizing fair...more
Last Friday, the Alternative Reference Rates Committee ("ARRC") published its recommended language to address LIBOR's probable cessation after 2021 in newly issued residential adjustable rate mortgages ("ARMs"). Minutes...more
The Situation: Student loan debt in the United States stands at an all-time high of approximately $1.5 trillion spread across more than 44 million borrowers. According to some observers, Massachusetts ranks 12th among states...more