Latest news
CFPB Adjusts HMDA Asset Exemption Threshold (UPDATED)
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA). Banks, savings associations and credit unions are not subject to the mortgage loan data collection and reporting requirements under HMDA for a calendar year if their assets as of December 31 of the prior calendar year did not exceed an asset threshold....By: Ballard Spahr LLP
UK Public Markets Monitor – Q4 2025
Below is our quarterly briefing covering the most important developments for UK PLCs, UK equity capital markets and UK public M&A in Q4 2025....By: Skadden, Arps, Slate, Meagher & Flom LLP
Energy 2025 - Year in Review
Geopolitical fractures and trade uncertainty persisted in 2025, yet cross‑border energy trade proved more essential than ever to global stability and growth....By: Baker Botts L.L.P.
Trends and Takeaways from the 2025 Credit CARD Act Report
On December 30, 2025, the CFPB published its seventh biennial Credit CARD Act report. As required by the CARD Act, the report discusses the state of the credit card market through 2024, with a particular focus on credit card usage and availability, the cost of credit accessed through credit cards, delinquency and collection, market dynamics, issuer practices such as rewards, installment plans, and deferred interest, and innovations in the credit card market....By: Orrick, Herrington & Sutcliffe LLP
Digital Asset Exchange Receives CFTC Approval for US Prediction Markets, Signaling an Opportunistic Outlook
On December 10, 2025, Gemini Space Station, Inc. (NASDAQ:GEMI) announced that the Commodity Futures Trading Commission (“CFTC”) approved the registration of its subsidiary—Gemini Titan, LLC—as a Designated Contract Market (“DCM”), making it the first crypto-native exchange to obtain the necessary regulatory license to operate a prediction market for U.S. retail investors....By: Sheppard Mullin Richter & Hampton LLP
CFPB Adjusts HPML Asset Exemption Threshold (UPDATED)
The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML). Regulation Z, which implements the TILA, generally requires creditors to maintain an escrow account for the payment of taxes and insurance on a first lien HPML. There are two creditor-based exemptions to the escrow account requirement....By: Ballard Spahr LLP
CFPB Reestablishes Position That Certain Earned Wage Access Programs Are Not “Credit”
On December 23, 2025, the Consumer Financial Protection Bureau (CFPB or “Bureau”) published an advisory opinion (the “2025 EWA Advisory Opinion”) concluding that certain earned wage access (EWA) programs do not constitute “credit” under the Truth in Lending Act (TILA) and Regulation Z. EWA, which has grown increasingly popular over the past several years, allows consumers to access a portion of wages that they have already earned but not received, prior to their scheduled payment date....By: Morrison & Foerster LLP
The Most Ignored Document: Your Plan Document
Every plan sponsor owns a plan document. Very few read it. Fewer understand it. And almost none use it as the operating manual it was designed to be....By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.
10 Key Focus Areas for UK-Regulated Financial Services Firms in 2026
In this publication, we explore some of the core focus areas for UK-regulated financial services firms in the year ahead....By: Latham & Watkins LLP
Private Credit ETFs for Retail Investors: Yield Potential, Liquidity Risks and Regulatory Scrutiny
Exchange-traded funds (ETFs) are a popular investment tool for investors, providing market access to a diverse set of industries and asset classes through a liquid investment strategy. While private credit markets have exploded in popularity and become a favored investment class for many institutional investors over the past 20 years, their illiquid nature and sizable investment requirements make the private credit space generally inaccessible to retail investors. However, a new class of ETFs...By: Katten Muchin Rosenman LLP
Alberta Court of Appeal Clarifies PPSA Priorities in Insolvency Sales
When a professional corporation operates with equipment owned personally by its director, how do secured creditors assert priority over proceeds from a receivership sale? A recent Alberta Court of Appeal decision in Royal Bank of Canada v Patterson Dental Canada Inc, 2025 ABCA 391 (Patterson Dental), offers important guidance on Personal Property Security Act, (PPSA) priority disputes, the treatment of purchase-money security interests (PMSI) and the proper distribution of holdbacks in...By: Bennett Jones LLP
A Leaner CAT for 2026: SEC Mulls Proposed $55–$73 Million Cost Reduction
After years of concern over the cost of the consolidated audit trail (CAT), Consolidated Audit Trail, LLC (CAT LLC) proposed a sweeping amendment that could reduce annual CAT operating expenses by as much as $73 million. On December 18, 2025, CAT LLC submitted to the Securities and Exchange Commission (SEC) a proposed amendment to the National Market System Plan Governing the Consolidated Audit Trail (the CAT NMS Plan) designed to materially reduce the ongoing costs of operating the CAT. The...By: Katten Muchin Rosenman LLP
Federal Reserve’s “Payment Accounts” Proposal: A Term Sheet for Industry Input
The Federal Reserve Board is requesting public input on a prototype for a special purpose Federal Reserve Bank account (a “Payment Account”) that eligible institutions could use to clear and settle their own payments directly. Interestingly, the Federal Reserve Board’s Payments Account proposal is structured as a term sheet, serving as a preliminary framework. This presents a critical window for industry stakeholders to influence the proposed Payment Account’s design, operational parameters, and...By: Wilson Sonsini Goodrich & Rosati
VC Firms Face New California Reporting Mandate
Venture capital and private equity fund managers with a California nexus that qualify as venture capital companies should begin collecting founder data for investments made in 2025 and must file their first report by April 1, 2026....By: Pillsbury Winthrop Shaw Pittman LLP
[Video] 31 Days to a More Effective Compliance Program: Day 7 - Clawbacks and Holdbacks
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this...By: Thomas Fox - Compliance Evangelist
New Restrictions on U.S. Outbound Investment Abroad
U.S. businesses involved in the U.S. defense industrial base have been historically protected from Foreign Direct Investment (FDI) by the Committee on Foreign Investment in the United States (CFIUS)....By: Womble Bond Dickinson
Enforcement News: Former Chief Operating Officer and Former Managing Partner Charged with Participating in An Alleged $300 Million Ponzi Scheme
This Blog has written about Ponzi schemes on numerous occasions. A Ponzi scheme is a type of investment fraud where returns to earlier investors are paid using investment capital from new or existing investors, rather than from legitimate profits earned through the enterprise’s business activities. Ponzi schemes persist by exploiting trust, promising high returns with little risk, and using money from new or existing investors to pay “profits” to earlier ones....By: Freiberger Haber LLP
BSA/AML Whistleblower Policy & Lawsuit Information
Federal law enforcement agencies including the Financial Crimes Enforcement Network (FinCEN) and U.S. Department of Justice (DOJ) rely heavily on whistleblowers to help them uncover violations of the Bank Secrecy Act (BSA) and other federal anti-money laundering (AML) statutes. Whistleblower complaints can assist these agencies with taking judicial or administrative action, and these actions can lead to monetary sanctions and other penalties....By: Oberheiden P.C.
EBA Letter On Outcome Of EBA's EU AI Act Mapping Exercise Against EU Banking And Payments Regulation
The European Banking Authority (EBA) has published a letter sent to the European Commission (EC) with the outcome of its EU AI Act mapping exercise. In January 2025, the EBA established a dedicated workstream to map the requirements on high-risk AI systems under the EU AI Act against relevant provisions in EU banking and payments regulation, with a focus on the use of AI for creditworthiness and credit scoring....By: A&O Shearman
Why Judge Jackson Is Wrong: The CFPB Cannot Be Lawfully Funded When the Federal Reserve Has No Profits
In her December 30, 2025 opinion in National Treasury Employees Union v. Vought (which we blogged about here), Judge Amy Berman Jackson concluded that the CFPB may continue to draw funding from the Federal Reserve System even when the Federal Reserve, on a combined basis, is losing money. According to the court, the statutory phrase “combined earnings of the Federal Reserve System” in 12 U.S.C. § 5497(a)(1) means all revenue earned by the Federal Reserve, not profits, and therefore permits CFPB...By: Ballard Spahr LLP
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