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Nov 1, 2024 | 
mondaq.com | Matthew Bisanz |Jeffrey Taft
The Board of Governors of the Federal Reserve System
("Federal Reserve") is implementing new reporting
requirements that will affect most bank holding companies and
foreign banking organizations ("banking
organizations").
As part of their annual regulatory filing, banking organizations
will be required to verify and reconcile the organization structure
chart on file with the Federal Reserve against the
organization's actual structure.
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Nov 1, 2024 | 
mondaq.com | Krista Cooley |Francis L. Doorley |Jeffrey Taft |Daniel Pearson
Legislation signed into law by California Governor Gavin Newsom
on September 24, 2024 will subject commercial debt collectors to
new compliance requirements starting in 2025. California Senate Bill 1286 extends the reach
of the state's Rosenthal Fair Debt Collection Practices Act
(the "Rosenthal Act"), California's primary law
regulating debt collection practices, to also cover certain small
business or commercial debts in addition to consumer debts.
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Sep 23, 2024 | 
mondaq.com | David L. Beam |Matthew Bisanz |Joseph A. Castelluccio |Jeffrey Taft
On September 17, 2024, the Federal Deposit Insurance Corporation
(FDIC) proposed extensive new recordkeeping requirements and other
compliance obligations (the "Proposal" ) for certain
types of deposit accounts frequently used by
banking-as-a-service (BaaS) platforms and other bank-fintech
partnerships.
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Sep 19, 2024 | 
lexology.com | David L. Beam |Matthew Bisanz |Joseph A. Castelluccio |Jeffrey Taft |Kelly F. Truesdale
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently used by banking-as-a-service (BaaS) platforms and other bank-fintech partnerships.
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Sep 17, 2024 | 
mondaq.com | Jeffrey Taft |Kristie D. Kully
On August 2, 2024, New Hampshire enacted legislation that
significantly revises its Motor Vehicle Retail Installment Sales
Act (the "Act"), effective July 1, 2024.
Unfortunately, that effective date is not a typographical error. The New Hampshire Banking Department apparently tried, during the
legislative process, to extend the effective date until January 1,
2025, but that extension did not make it into the enacted bill.
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Sep 16, 2024 | 
jdsupra.com | Daniel Pearson |Jeffrey Taft
Missouri has enacted the nation’s ninth state commercial finance disclosure law, regulating the providers and brokers of certain commercial financing transactions. Signed by Governor Mike Parson on July 11, 2024, Missouri Senate Bill 1359 enacted the Missouri Commercial Financing Disclosure Law (the “Law”), imposing disclosure and registration requirements for providers and brokers, respectively, of qualifying commercial financing.
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Sep 16, 2024 | 
mondaq.com | Daniel Pearson |Jeffrey Taft
Missouri has enacted the nation's ninth state commercial
finance disclosure law, regulating the providers and brokers of
certain commercial financing transactions. Signed by Governor Mike
Parson on July 11, 2024, Missouri Senate Bill 1359 enacted the
Missouri Commercial Financing Disclosure Law (the "Law"),
imposing disclosure and registration requirements for providers and
brokers, respectively, of qualifying commercial financing.
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Sep 13, 2024 | 
jdsupra.com | Kris D. Kully |Jeffrey Taft
On August 2, 2024, New Hampshire enacted legislation that significantly revises its Motor Vehicle Retail Installment Sales Act (the “Act”), effective July 1, 2024. Unfortunately, that effective date is not a typographical error. The New Hampshire Banking Department apparently tried, during the legislative process, to extend the effective date until January 1, 2025, but that extension did not make it into the enacted bill.
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Sep 2, 2024 | 
mondaq.com | Jeffrey Taft |Kristie D. Kully
In response to the significant ambiguities raised by New
Hampshire's recent amendments to its Motor Vehicle Retail
Installment Sales Act — not to mention their immediate
effectiveness and draconian liability provisions — the
state's Banking Department has issued several nuggets of
guidance.
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Aug 28, 2024 | 
mondaq.com | Jeffrey Taft |Kristie D. Kully
On August 2, 2024, New Hampshire enacted legislation that
significantly revises its Motor Vehicle Retail Installment Sales
Act, effective July 1, 2024.
Unfortunately, that effective date is not a typographical error. The New Hampshire Banking Department apparently tried during the
legislative process to extend the effective date until January 1,
2025, but that extension did not make it into the enacted bill.
