Blog
New NY DFS Regulations on Small Non-Bank Loans
On December 23, 2020, then Governor Andrew Cuomo signed N.Y. CLS Fin. Serv. ยงยง 801-812 (the “Law”) mandating truth-in-lending style disclosure for small non-bank loans of $2.5 million or less, but only going into effect when final regulations under the Law are published. The N.Y. Department of Financial Services (the “DFS”) adopted final regulations on... Read more »
FTC Proposes to Ban Non-Competes
On January 5, 2023, the Federal Trade Commission (the “FTC”) proposed a rule that would effectively ban non-compete clauses between employers and “workers,” to include a broad range of workers such as executives, independent contractors, interns, externs, volunteers, apprentices, and sole proprietors who provide services to a client or customer. Even some unusually broad non-disclosure... Read more »
FinCEN Issues Final Beneficial Ownership Rule
On September 22, 2022, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury issued a final rule (the “Rule”) under the Anti-Money Laundering Act and the Corporate Transparency Act thereof. The Rule requires certain entities to report beneficial ownership. “Reporting companies” are (i) domestic entities created by filing with a state... Read more »
SEC Fails to Resolve Confusion Over Securities and Crypto Assets
On July 21, 2022, the Securities and Exchange Commission (the “SEC”) filed a complaint against a former employee of Coinbase, a trading platform for digital assets, and two of his friends, alleging insider trading of securities. The complaint therefore identifies certain digital investment contracts as securities, a position the SEC has taken for some time.... Read more »