On Dec. 21, 2020, Congress approved H.R. 133, referred to as the “Consolidated Appropriations Act, 2021” (the Act). The legislation, signed into law by President Trump on Dec. 27, 2020, enhances and expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act of 2020 (the CARES Act) (H.R. 748) and changes the Paycheck Protection Program (PPP) administered by the U.S. Department of the Treasury’s Small Business Administration (SBA) by (i) authorizing additional liquidity…

On Dec. 18, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) that would impose on banks and money services businesses (MSBs) new recordkeeping, reporting, and identity verification requirements for certain transactions involving convertible virtual currency (CVC) and digital assets with legal tender status (LTDA) held in “unhosted wallets,” i.e., wallets not hosted by a financial institution, or “otherwise covered wallets,” i.e., wallets held at a financial…

The National Association of Insurance Commissioners (NAIC) Fall 2020 National Meeting was held virtually on Dec. 3-4 and Dec. 7-9. Greenberg Traurig attended many of the sessions, and we are pleased provide you with summaries of some of the discussions and actions that took place during the national meeting through the following link: GT Recap | NAIC Fall 2020 National Meeting. If you have any questions, please contact Fred Karlinsky or Rich Fidei.…

On Sept. 25, 2020, California Gov. Gavin Newsom signed into law the California Consumer Financial Protection Law (CCFPL), which was passed by the California Legislature Aug. 31, 2020. The provisions of the CCFPL become effective Jan. 1, 2021. The stated intent of the CCFPL is to “strengthen consumer protections by expanding the ability of the State of California to improve accountability and transparency in the California financial system, provide consumer financial education, and protect…

Natural Disasters are getting worse. In the wake of disasters such as Hurricane Laura, Hurricane Sally, and the wildfires that recently ravaged the western region of the United States, millions of Americans are seeking to donate to those impacted, and/or invest in infrastructure involved in cleanup, repair, and recovery efforts.1 Capitalizing on charity and comradery, fraudulent fundraisers and investments have become more prevalent. These schemes are created with the intention of taking advantage of…

On Oct. 23, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (FRB) (FinCEN and the FRB collectively, the Agencies), issued a joint notice of proposed rulemaking (Proposed Rule) that would amend the Recordkeeping Rule and Travel Rule regulations issued under the Bank Secrecy Act (BSA). Read the full GT Alert, “FRB and FinCEN Propose Significant Amendments to Recordkeeping and Travel …

On Oct. 7, 2020, the U.S. Securities and Exchange Commission (SEC) held an open meeting and issued a notice proposing a conditional exemption from securities broker-dealer registration under Section 15 of the Securities Exchange Act of 1934 for “finders” who assist entrepreneurs and issuers in raising capital through private placements sold to accredited investors (the proposal). The proposal would create two tiers of finders who, if all conditions are satisfied, would allow such finders to…