On Nov. 9, 2022, the New York Department of Financial Services (NYDFS) issued a proposed second amendment to its 2017 cybersecurity regulation for financial service companies.[1] In July 2022, NYDFS issued a draft version of the changes, but the current amendment has significant changes. Most of the proposed changes will take effect 180 days…

On Sept. 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule, effective Jan. 1, 2024, implementing the beneficial ownership information reporting provisions of the Corporate Transparency Act.

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On May 12, 2022, Gov. Ron DeSantis signed bill CS/HB 273 (the Bill), amending Florida’s money services business (MSB) laws (i.e., Chapter 560 of the Florida Statutes) to, among other things, define “virtual currency” and address transactions involving “virtual currency.” The amendments to the Florida MSB laws take effect Jan. 1, 2023.

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As nonbanks comprise an ever-greater share of the consumer-finance market, on April 25, 2022, the Consumer Financial Protection Bureau (CFPB, or the Bureau) announced it would invoke its “unused” legal authority to examine nonbanks “that pose risks to consumers.”

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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.

In This Issue:

Spotlight on…

GT Insights

Upcoming Events

Q&A with GT’s Ben Saul: Recent CFPB Developments and Outlook

Sequel to Spokeo: Supreme Court to Address Standing…

The Division of Examinations (the Division) (formerly known as the Office of Compliance Inspections and Examinations, or OCIE) of the U.S. Securities and Exchange Commission (SEC) released its annual list of 2021 Examination Priorities on March 3, 2021.

Many of the Division’s 2021 examination priorities, including focus on conflicts of interest for brokers and…

New regulations have been recently issued pursuant to Mexico’s Law to Regulate Financial Technology Institutions, published March 10, 2018. These new regulations apply to a significant group of financial entities and require the establishment of application programming interfaces (“APIs”) to enable connectivity, access, and sharing of certain data.

All financial entities explicitly mentioned by the…

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released its annual list of 2020 Examination Priorities on Jan. 7, 2020. Many of OCIE’s 2020 examination priorities, including the focus on retail investors, fraud, conflicts (and related disclosures), among others, are perennial risk areas that OCIE routinely prioritizes.…

In the summer of 2015, the New York State Department of Financial Services (DFS) finalized its regulatory framework for virtual currency firms seeking to conduct certain virtual currency (VC) business activities in the state. Since then, it has issued two dozen licenses and charters involving virtual currency transmission (VC licenses). To promote efficiency and reflect…

On Oct. 16, 2019, Bermuda Premier the Hon. E. David Burt JP, MP announced that Bermuda has committed to accept, for payment of government taxes, fees, and services, 1:1 U.S.-dollar-backed digital currencies of entities licensed by the Bermuda Monetary Authority (BMA) under the 2018 Digital Asset Business Act (DABA), becoming the first nation to do…