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Dec 31, 2024 | 
jdsupra.com | Kelly F. Truesdale
On December 26, 2024, a panel of the US Court of Appeals for the Fifth Circuit vacated an order issued by a different panel just days before that had stayed the nationwide preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementing regulations.
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Dec 11, 2024 | 
jdsupra.com | Kelly F. Truesdale
On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the Corporate Transparency Act (CTA) and its implementing regulations—are not required to file beneficial ownership reports for as long as the current, nationwide injunction of the CTA remains in effect.1 Further, FinCEN noted that reporting companies will have no liability for...
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Dec 10, 2024 | 
jdsupra.com | Matthew Bisanz |Brad Resnikoff |Kelly F. Truesdale
On December 3, 2024, the US District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementing regulations nationwide, concluding that the CTA is likely unconstitutional as it is outside Congress’s power.
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Dec 10, 2024 | 
mondaq.com | Matthew Bisanz |Gina M. Parlovecchio |Brad Resnikoff |Kelly F. Truesdale
On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the Corporate Transparency Act (CTA) and its implementing regulations—are not required to file beneficial ownership reports for as long as the current, nationwide injunction of the CTA remains in effect.1 Further, FinCEN noted that reporting companies will have no liability for...
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Dec 5, 2024 | 
mondaq.com | Matthew Bisanz |Brad Resnikoff |Kelly F. Truesdale
On December 3, 2024, the US District Court for the Eastern
District of Texas entered a preliminary injunction suspending
enforcement of the Corporate Transparency Act (CTA) and its
implementing regulations nationwide, concluding that the CTA is
likely unconstitutional as it is outside Congress's power.
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Oct 21, 2024 | 
mondaq.com | Matthew Bisanz |Kelly F. Truesdale
Last month, the FDIC
proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech
partnerships, including some partnerships for programs that do not
promise FDIC coverage to end customers. This webinar will analyze
the proposed rules, and identify ways we think it could impact
these partnerships (including some that may not be obvious).
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Oct 17, 2024 | 
lexology.com | Matthew Bisanz |Kelly F. Truesdale
Click here to listen to the audio. Last month, the FDIC proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech partnerships, including some partnerships for programs that do not promise FDIC coverage to end customers. This webinar will analyze the proposed rules, and identify ways we think it could impact these partnerships (including some that may not be obvious).
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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 10, 2024 | 
mondaq.com | Matthew Bisanz |Adam D. Kanter |Brad Resnikoff |Kelly F. Truesdale
On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) finalized a rule establishing anti-money laundering (AML) compliance obligations for certain investment advisers (the "Final Rule").1 FinCEN largely adopted the substance of the proposed rule2 (the "Proposal")—discussed in our previous3 FinCEN has generally applied the BSA's AML compliance obligations only to specific types of financial institutions for which FinCEN has established rules governing the related AML compliance...
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Apr 16, 2024 | 
mondaq.com | Matthew Bisanz |Kelly F. Truesdale |Jeffrey Taft |David L. Beam
At the end of March, components of the US Federal Reserve System
("FRS" or the "Fed") prevailed in two lawsuits
brought by depository institutions seeking master
accounts.1 These decisions have significant implications
for the Fed's authority and discretion to grant or deny master
account requests, as well as for the legal rights and remedies of
applicants.
