Understanding Scope of Practice
Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
Starting May 31, National Futures Association (“NFA”) Members and Associates that engage in digital asset commodity activities must comply with NFA Compliance Rule 2-51 (“Rule 2-51” or the “Rule”) regarding anti-fraud, just...more
FDIC Takes Action Against False or Misleading Crypto-Related Representations - On August 19, the FDIC issued letters (the Letters) to five companies demanding that they cease and desist from making false and misleading...more
The CFPB has issued a policy statement regarding its approach to supervision and enforcement of remittance transfers during the COVID-19 pandemic....more
On August 21, 2019, the Securities and Exchange Commission (SEC) voted 3 to 2 to adopt new interpretive guidance (the “Voting Interpretation”) applicable to investment advisers regarding their proxy voting responsibilities as...more
On July 23, 2019, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert outlining its observations and recommendations following an examination initiative that focused on oversight practices...more
Avoiding financial exploitation of older investors has been on our regulators’ radar screens for several years. With new rules proposed in October 2015, FINRA seeks to make investing safer for seniors and other vulnerable...more
New York City banks are breathing a sigh of relief after a federal judge ruled that they would not have to provide detailed servicing disclosures under a preempted city law. The law, a gloss on top of the federal Community...more
On May 12, 2015, the Joint Committee of the three European Supervisory Authorities (ESAs) published a report detailing its findings and recommendations regarding the disclosure requirements and obligations relating to due...more
FINRA’s Retrospective Rule Review Process Continues. On April 16, FINRA announced that the FINRA Board of Governors had authorized FINRA to publish a regulatory notice requesting comment on proposed amendments to Rules 2210...more
In a new compliance bulletin (2015-01), the CFPB reminds supervised financial institutions, including nonbanks, of their obligations regarding the disclosure of confidential supervisory information (CSI)....more