Regulatory Compliance

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On March 27, 2025, the Federal Trade Commission (FTC) filed a lawsuit and proposed settlement order resolving claims against Cleo AI, a fintech that operates a personal finance mobile banking application through which it offers consumers instant or same-day cash advances. The FTC alleges that Cleo deceived consumers about how much money they could get and how fast that money could be available, and that Cleo made it difficult for consumers to cancel its subscription service.…

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On Jan. 23, 2025, the U.S. Supreme Court granted the U.S. government’s request for a stay (SCOTUS Order) of the nationwide preliminary injunction of the Corporate Transparency Act (CTA) issued by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop, Inc. v. McHenry. According to the brief order…

In October 2024, the California DFPI finalized regulations for providers of income-based advances (Earned Wage Access or EWA), clarifying registration requirements under the California Consumer Financial Protection Law (CCFPL). These changes impose new compliance obligations for businesses offering EWA products to California consumers.

This GT Alert summarizes the regulation’s highlights.

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The Commodity Futures Trading Commission (CFTC) undertook a series of initiatives in 2024 to address CFTC registrants’ and other industry participants’ use and application of AI technologies. While these actions do not constitute formal rulemaking or adoption of new regulations, they underscore CFTC’s continued awareness of and attention to the potential benefits and risks of…

On Dec. 26, 2024, the nationwide preliminary injunction that a Texas district court issued in Texas Top Cop Shop, Inc. v. Garland against enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting rule was reinstated by the merits panel of the Fifth Circuit assigned to the appeal (a different panel…

On Nov. 21, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule), pursuant to 12 U.S.C. § 5514(a)(1)(B), to establish supervisory authority over nonbank entities identified as larger participants in the general-use digital consumer payment applications market. While the CFPB already has enforcement power over digital funds transfer and payment wallet app…

A Texas district court has issued a nationwide preliminary injunction four weeks before a key Jan. 1, 2025, reporting deadline for the Corporate Transparency Act (CTA) that, while in effect, enjoins enforcement of the CTA’s beneficial ownership information (BOI) reporting requirements. The Texas court explicitly stated that this injunction “should apply nationwide.”

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On Sep. 4, 2024, FinCEN published a final rule (Final Rule) adding certain RIAs and ERAs (collectively, Covered Advisers) to the definition of “financial institution” under the regulations implementing the BSA, and imposing on Covered Advisers broad AML and CFT program requirements, as well as other BSA recordkeeping and reporting requirements. The Final…

On Nov. 6, 2024, the Federal Trade Commission (FTC) released an administrative complaint and accepted a proposed consent order resolving claims against GGL Projects, Inc., an AI-enabled customer review platform that does business as Sitejabber. The FTC alleges that Sitejabber provides its ecommerce clients with the ability to (a) collect ratings and reviews from consumers…

This article covers the standard compliance policies and procedures that real estate fund managers should consider adopting, whether in consultation with attorneys who have experience with registered investment advisers (RIAs) or outside consultants who specialize in preparing compliance manuals. The list in this article is only a start; a manager’s particular real estate sector or…