On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program rules include banks, casinos and card clubs (casinos), money services
The Consumer Financial Protection Bureau’s interpretive rule for Buy Now, Pay Later products classifies them as “credit cards” and their providers as “card issuers” and “creditors” under the Truth in Lending Act and Regulation Z. The rule is now
On Aug. 15, 2024, a federal court dismissed a proposed class action against financial analysis website Seeking Alpha, Inc. (Seeking Alpha). The lawsuit was brought in July 2023 by subscribers who accused Seeking Alpha of operating as an
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act and related rules, absent an exemption, most private fund managers are required to register with the US Securities and Exchange Commission (SEC) or, in some cases, state securities authorities. Under
In the latest installment of its ongoing “off-channel” communications sweep, on Aug. 14, 2024, the Securities and Exchange Commission announced settlements totaling $393 million with 26 investment advisers and brokers-dealers for widespread use of texting, messaging applications, and other off-channel
On Aug. 9, 2024, the Securities and Exchange Commission initiated administrative and cease-and-desist proceedings against a U.S. registered investment adviser (the Adviser). This action resulted from the Adviser’s failure to comply with the SEC amended Marketing Rule under the Investment
On July 30, 2024, the SEC announced it had reached a settlement agreement with Western, a dually registered investment adviser and broker-dealer providing investment advice and brokerage services to retail customers, for allowing a former representative to engage in a
The SEC finalized the Private Funds Rule in August 2023, imposing compliance and regulatory requirements on private fund advisers, as summarized in this GT Alert. The Private Funds Rule requires quarterly disclosure statements to include information about performance fees,
The CTA mandates that, starting on Jan. 1, 2024, certain U.S. legal entities and foreign entities registered to do business in the United States (collectively, Reporting Companies) disclose certain BOI to the U.S. Department of the Treasury’s Financial Crimes Enforcement
On June 17, 2024, the FTC filed a federal court complaint against Adobe and two of its executives. The complaint alleges that Adobe deceived consumers by failing to adequately disclose that its annual subscription plans were subject to an ETF
