In 2015, the New York Department of Financial Services (NYDFS) finalized rules creating the BitLicense for virtual currency exchanges operating in New York state. New York is currently the only state to have a licensing regime specifically for virtual currency exchanges.
The industry has bemoaned the BitLicense since it was proposed. Critics say that the
On June 22, 2020, in Liu v. SEC, the Supreme Court affirmed in an 8-1 ruling that the Securities and Exchange Commission may continue to pursue disgorgement awards under the federal securities law provided that the award is capped at the defendant’s net profits, and further, provided that the award is made for the
On May 20, 2020, the Office of the Comptroller of the Currency (OCC), which regulates national banks, released a Final Rule intended to strengthen and modernize the implementation of the Community Reinvestment Act, 12 U.S.C. § 2901 et seq. (the CRA). The CRA was originally enacted in 1977 to reverse decades of financial “redlining”
On June 3, 2020, Congress passed the PPP Flexibility Act to loosen requirements for loan forgiveness for CARES Act Paycheck Protection Program (PPP) borrowers. The new forgiveness rules will allow borrowers to extend the period for spending the loan proceeds to 24 weeks from the date of disbursement, an increase from the eight-week period originally
On May 22, the Small Business Administration and the Treasury Department released its latest guidance in the form of two interim final rules on loan forgiveness: “Business Loan Program Temporary Changes; Paycheck Protection Program –Requirements – Loan Forgiveness” and “Business Loan Program Temporary Changes; Paycheck Protection Program – SBA Loan Review Procedures
This evening the SBA issued new FAQ 47 extending the repayment date for the safe harbor to May 18, 2020. View the full FAQs here.
For more information and updates on the developing COVID-19 situation, visit GT’s Health Emergency Preparedness Task Force: Coronavirus Disease 2019 or GT’s Economic Stimulus Team.
This morning the SBA issued an important new FAQ 46 on how it intends to review the good faith necessity certification required for PPP loans. The safe harbor for return of PPP loans expires tomorrow, May 14, and companies should carefully consider the newest guidance as they weigh whether to return loans. View the full
Many counterparties are dealing with the impact of market volatility, unprecedented margin calls and the combined effects on their financial contracts, many of which are active master agreements executed years ago. It is important to check for terms like, “may” verses “shall”, applicable notice requirements and cure periods associated with default triggers and finally, the
On March 4, 2020, the Securities and Exchange Commission (SEC) announced its proposal to harmonize, simplify, and improve the exempt offering framework under the Securities Act of 1933 (the “Securities Act”).1 The SEC’s proposals are the result of the responses submitted to the SEC in connection with the concept release issued June 18, 2019, soliciting