Blog
SEC Exam Priorities – 2023/24
On October 16, 2023, the Division of Examinations (the “Division”) of the Securities and Exchange Commission (the “SEC”) released its 2023/24 exam priorities, moving the annual notice up a few months to coincide better with the SEC fiscal year. Among other things, the notice confirmed that one of the priorities again will be to examine... Read more »
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. The Rule requires certain entities to report beneficial ownership. “Reporting Companies” are (i) domestic entities created by filing with a state secretary... Read more »