By a 3-2 party-line vote, on Aug. 23, 2023, the Securities and Exchange Commission adopted some of the most significant new rules under the Investment Advisers Act of 1940, as amended, since the elimination of the old “15 or fewer” exemption that most private fund advisers had relied upon prior to the 2010 enactment of
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On July 27, 2023, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued an interagency notice of proposed rulemaking to implement aspects of the final components of the Basel III agreement, also known as the Basel III end game.
A holding subjecting Term Loan Bs to securities regulation would have a profound effect on the $1.4 trillion market for syndicated term loans and on financial institutions at a time of limited liquidity.
Continue Reading Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC Views
On March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank, Santa Clara, CA (SVB) and appointed the Federal Deposit Insurance Corporation (FDIC) receiver of SVB. To protect depositors, the FDIC transferred all the deposits and substantially all assets of SVB to Silicon Valley Bridge Bank, National Association (SVBB), a
On Dec. 13, 2022, the Department of Justice announced that Danish global financial institution Danske A/S (Danske Bank) pled guilty and agreed to forfeit $2 billion to resolve an investigation into fraudulent representations it made to U.S. banks about its anti-money laundering (AML) controls in Estonia. As part of a parallel proceeding, the SEC also
On May 19, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an interpretive rule (Section 1042 Interpretive Rule 5 19 2022) confirming that the Consumer Financial Protection Act of 2010 (CFPA) provides states with wide-ranging powers—independent of the Bureau—to enforce federal consumer protection laws.
On May 16, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a report regarding COVID-19 response metrics based upon its “observations from data obtained by 16 large mortgage servicers” from May through December 2021 (Report). This report is a follow-up to an August 2021 report regarding the Bureau’s observations from data obtained from
Welcome to the Spring 2021 issue of Greenberg Traurig’s Financial Services Insights Newsletter. This newsletter reviews certain significant cases and legal developments affecting the financial services industry.
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Q&A with GT’s Ben Saul: Recent CFPB Developments and Outlook
Sequel to Spokeo: Supreme Court to Address Standing
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
On Sept. 25, 2020, the SEC issued a No-Action Letter to FINRA, in response to a previously issued Joint Statement by the SEC and FINRA. This No-Action Letter detailed how broker-dealers could operate alternative trading systems that trade digital assets without garnering enforcement action from the SEC for not meeting the custody requirements required under