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New Florida Legislation Proposes Notification Requirements for Certain Financial Institutions When They Terminate, Suspend, or Take Similar Action to ‘Restrict’ Customer Account Access

By David C. Ashburn, Fred E. Karlinsky, Marina Olman-Pal, Claudio J. Arruda & Tiffanie Monplaisir on December 12, 2023
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Florida State Capitol

On Nov. 20, 2023, Florida Rep. Bob Rommel (R-Naples) introduced Florida House Bill 585, which proposes to require certain financial institutions operating in Florida to file a “termination-of-access report” with the OFR when they terminate, suspend, or take any “similar action restricting” a customer’s account access, unless an exemption applies.

Continue reading the full GT Alert.

Photo of David C. Ashburn David C. Ashburn

David C. Ashburn is Managing Shareholder of the Tallahassee Office. He provides state and federal regulatory counsel and administrative litigation representation to clients in the health care, managed care, financial services and insurance-industries. His understanding of governmental regulatory processes also enables him to…

David C. Ashburn is Managing Shareholder of the Tallahassee Office. He provides state and federal regulatory counsel and administrative litigation representation to clients in the health care, managed care, financial services and insurance-industries. His understanding of governmental regulatory processes also enables him to counsel buyers and sellers of regulated businesses and the lenders and private equity groups that finance those transactions. The types of clients that David advises include:

  • Institutional health care providers such as hospitals, ambulatory surgery centers, assisted living facilities, nursing homes, home health agencies, durable medical equipment providers, sober homes and hospices
  • Continuing care retirement communities
  • Financial services providers, including financial advisers and brokers
  • Insurers, health maintenance organizations (HMOs) and third-party administrators (TPAs)
  • Lenders and investors, including financial institutions, private equity funds and real estate investment trusts
  • Physician practices, including large multi-specialty practices
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Photo of Fred E. Karlinsky Fred E. Karlinsky

Fred Karlinsky is a Shareholder and Global Co-Chair of Greenberg Traurig’s Insurance Regulatory and Transactions Practice Group. Fred has nearly 30 years of experience representing the interests of insurers, reinsurers and a wide variety of other insurance-related entities. He is a recognized authority…

Fred Karlinsky is a Shareholder and Global Co-Chair of Greenberg Traurig’s Insurance Regulatory and Transactions Practice Group. Fred has nearly 30 years of experience representing the interests of insurers, reinsurers and a wide variety of other insurance-related entities. He is a recognized authority on national insurance regulatory and compliance issues and has taken a leadership position in many insurance trade organizations. Recognized as the only Band 1 Florida insurance lawyer by Chambers & Partners and one of the most influential leaders in Florida politics by City & State Florida and INFLUENCE Magazine, Fred has in-depth knowledge of insurance compliance matters and has been a primary strategist in virtually all types of Florida insurance-related legislative initiatives. Fred has also been listed in The Best Lawyers in America, Super Lawyers, Florida Trend 500 and Florida Trend’s “Legal Elite” for his work in insurance law. In addition to his role with Greenberg Traurig, Fred has been an Adjunct Professor of Law at Florida State University College of Law since 2008, where he teaches a course on Insurance Law and Risk Management. Fred currently chairs the Florida Supreme Court Judicial Nominating Commission, which he has served on since 2014. Four of the seven current sitting Justices of the Florida Supreme Court have been appointed during Fred’s tenure on the JNC.

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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Claudio J. Arruda Claudio J. Arruda

Claudio J. Arruda advises domestic and international financial services firms and institutions, including banks, broker-dealers, Fintech companies, and investment advisory firms on a broad range of regulatory issues, as well as general corporate matters. He represents these institutions on matters related to the…

Claudio J. Arruda advises domestic and international financial services firms and institutions, including banks, broker-dealers, Fintech companies, and investment advisory firms on a broad range of regulatory issues, as well as general corporate matters. He represents these institutions on matters related to the applicability and compliance with state and federal banking, and consumer laws and regulations.

Claudio also advises a wide range of investment advisers on all aspects of securities regulatory compliance, particularly including new and existing SEC rules, and has experience advising clients on corporate governance and general corporate matters.

In addition, Claudio represents public and private corporations in negotiating cross-border financing projects. He also has experience assisting in securities enforcement matters and FCPA-related investigations at the U.S. Securities and Exchange Commission (SEC).

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Photo of Tiffanie Monplaisir Tiffanie Monplaisir

Tiffanie Monplaisir is a Practice Group Attorney in the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the

…

Tiffanie Monplaisir is a Practice Group Attorney in the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal and state regulatory landscape governing payments, lending, licensing, and consumer financial services. Tiffanie’s practice includes advising banks, FinTech and digital payment companies, money services businesses, payment processors, cryptocurrency businesses, and digital asset companies on a wide range of regulatory matters including licensing, crafting innovative solutions for Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance programs and related policies and procedures. Tiffanie also works on nationwide state money transmitter, lending, servicing, and other license acquisition projects.

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  • Posted in:
    Corporate & Commercial, International
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source
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