On October 9, a Florida state senator introduced SB 146, which would add a new section to the Florida Consumer Finance Act (CFA), attempting to curb evasion of the CFA. SB 146 would treat all payments incident to the loan as...more
Florida SB 146, a bill that would add a “Predatory loan prevention” section to the Florida Consumer Finance Act has been introduced in the Florida Senate, seeking to curb bank-model lending programs and codify a “true lender”...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more
The U.S. Securities and Exchange Commission (“SEC”) brought an action in the United States District Court for the Southern District of New York against five alleged promoters of a digital asset called BitConnect, claiming...more
Increasingly, lenders are interested in pursuing proactive efforts to increase lending opportunities for members of African-American, Hispanic and other communities that may have traditionally been underserved. These...more
Earlier in March, the Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA) and Office of the Comptroller of the Currency (OCC and collectively with the FRB,...more
In light of COVID-19, the Canadian government is offering financial relief by way of various forms. Relief includes, but is not limited to the following: Wage Subsidy Program. The federal government is offering a 75% wage...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) became law on March 27, 2020. The economic stimulus package in the CARES Act includes federal funding for business stimulus across three broad categories. ...more
On April 9, 2020, the Federal Reserve Board of Governors announced several extraordinary measures to support the national economy during COVID-19. Among these is the Main Street Lending Program, which will enable up to $600...more
In support of financial institutions and borrowers during the COVID-19 pandemic, the newly enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes a number of provisions permitting lenders to suspend,...more
The Coronavirus Aid, Relief, and Economic Security Act, commonly known as the CARES Act (the “Act”), enacted March 27, 2020, contains several interrelated elements that employers should consider when making decisions about...more
A hot topic of discussion in payroll offices around the country is the prospect of new services that provide workers with immediate access to their wages for hours they have worked but which aren’t due to be paid until after...more
A watershed moment is “the exact moment that changes the direction of an activity or situation . . . a dividing point, from which things will never be the same.” The Second Circuit Court of Appeals’ 2015 decision in Madden v....more