On Jan. 24, 2024, the Consumer Financial Protection Bureau (CFPB) released a proposed rule that would, if finalized in its present form, prohibit financial institutions from charging non-sufficient funds (NSF) fees when consumers initiate transactions that are instantaneously or near-instantaneously declined. Under the proposed “Fees for Instantaneously Declined Transactions rule (the “NSF Fee Rule”), charging…

Earlier this week, the SEC issued a Press Release announcing a Rule Proposal that would require SEC-registered investment advisers to adopt written business continuity and transition plans (BCP) as part of their compliance program.  The comment period on the Rule Proposal is expected to close in September.  Under the proposed rule, an adviser’s written BCP…