Seyfarth Synopsis: DOJ issues useful new Guide to help small governmental entities understand the new web and mobile app accessibility requirements under Title II of the ADA....more
Starting in 2024, many entities that are created in or registered to do business in the United States will be required to file BOI reports with FinCEN. With the effective date fast approaching, criticism surrounding...more
Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more
The U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking on September 27, 2023 to amend the final Beneficial Ownership Information (“BOI”) Reporting Rule to...more
The U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) has released its Small Entity Compliance Guide in preparation for beneficial ownership information reporting pursuant to the Corporate Transparency...more
The Financial Crimes Enforcement Network (“FinCEN”) has published a new Small Entity Compliance Guide (“Guide”) for compliance with the Beneficial Ownership Information Reporting Rule (“Reporting Rule”), 31 CFR 1010.380. The...more
As previously reported, in April 2020 the CFPB released a final rule to increase the threshold to report closed-end mortgage loans under the Home Mortgage Disclosure Act (HMDA) from 25 to 100 originated loans in each of the...more
As previously reported, in October 2019 the CFPB issued a final rule under the Home Mortgage Disclosure Act (HMDA) to...more
The CFPB published a policy statement in today’s Federal Register to announce that, going forward, it is establishing a new “Compliance Aids” designation for certain Bureau guidance. The policy statement becomes applicable...more
Last week, the CFPB released its most recent update to the Prepaid Rule Small Entity Compliance Guide. The new version includes expanded information regarding the process for complying with the Prepaid Rule’s requirement to...more
The CFPB has issued a new small entity compliance guide: “Payday, Vehicle Title and High-Cost Installment Lending Rule: Payment-Related Provisions.”...more
The CFPB recently issued revised versions of the small entity compliance guides for the Loan Originator Rule and the Home Ownership and Equity Protection Act (HOEPA) Rule....more
The CFPB recently issued a revised version of the Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guide to reflect a partial exemption to Home Mortgage Disclosure Act (HMDA) requirements made by the Economic...more
Editor's Note - Treasury Issues Recommendations to Modernize the Community Reinvestment Act. On April 3, the U.S. Department of the Treasury released a report containing its recommendations for modernizing the Community...more
As it has done for other CFPB rules, the CFPB has published a small entity compliance guide for its prepaid card rule. The final rule is generally effective on October 1, 2017. ...more
Editor's Note - President Trump Signs Executive Order to Reduce Regulation and Control Regulatory Costs. On January 30, President Trump signed an executive order (Executive Order) designed to reduce the regulatory...more
The Securities and Exchange Commission recently released a Small Entity Compliance Guide for Issuers that provides a helpful summary of the exemption....more
At a panel discussion today on the prepaid account rule, held as part of the meeting of the American Bar Association Committee on Consumer Financial Services in Carlsbad, CA, Kristine Andreassen, the team leader for the CFPB...more
Editor's Note - Never Satisfied. Despite the Securities and Exchange Commission’s announcement that, in its just completed fiscal year 2016, it filed a record 868 enforcement actions reprimanding misconduct by companies...more
On July 31, 2014, without much public attention, President Obama issued a far-reaching Executive Order, No. 13673, which requires bidders on federal contracts to disclose adverse labor law decisions under more than a dozen...more
Earlier this month, the SEC released a small entity compliance guide for issuers regarding its recently passed crowdfunding regulation to help provide issuers with some additional clarity. ...more
Yesterday, May 24, 2016, the Staff of the Securities and Exchange Commission published a Small Entity Compliance Guide that is intended to help issuers navigate the changes to the Exchange Act Section 12(g) threshold in light...more
On May 13, 2016, the SEC issued new Compliance and Disclosure Interpretations (“C&DIs”) on Rules 100 (Crowdfunding Exemption and Requirements), 201 (Disclosure Requirements), 204 (Advertising) and 205 (Promoter Compensation)...more
The CFPB released the Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guide on December 1, 2015. According to the CFPB, the purpose of the Compliance Guide is to provide an accessible summary of Regulation C,...more
This week marks the three-month anniversary of the effective date of Regulation A. Of course, given this limited experience, it may be premature to comment on market developments. Instead, below we summarize significant...more