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New York Bankruptcy Court Approves Insider DIP Litigation Financing
The ability of a bankruptcy trustee or chapter 11 debtor-in-possession ("DIP") to obtain financing may be crucial to the success of a chapter 11 case as a means of funding operations or distributions under a plan of reorganization. As demonstrated by a ruling handed down by the U.S. Bankruptcy Court for the Southern District of New York, such financing may also be necessary and appropriate to finance litigation that can generate value for the bankruptcy estate, even if the financing is provided...By: Jones Day
SEC Staff Issues New CFI (formerly C&DI) Clarifying ATM Offering Capacity Following “Baby Shelf” Transition
Recently, the SEC’s Division of Corporation Finance published new Corporation Finance Interpretation (CFI, formerly referred to as Compliance and Disclosure Interpretations, or C&DIs) 116.26, addressing a discrete but practically important question for issuers conducting at-the-market (ATM) offerings on Form S-3...By: Foley Hoag LLP - Public Companies & the Law
ICI Proposes Subscription Data Framework for Retail Alternatives
The Investment Company Institute (ICI) released a white paper introducing a proposed subscription data framework (the “Framework”) for retail alternative investments. Developed by its Retail Alternatives Working Group, the Framework aims to standardize data formats and definitions used in subscription documents, improving interoperability across systems and supporting more efficient distribution....By: Mayer Brown Free Writings + Perspectives
Weekly Blockchain Monitor – March 2026 #4
US Payments Companies Continue Crypto Acquisitions, Integrations - A major U.S. financial services company that operates one of the world’s largest payment networks recently announced “a definitive agreement to acquire BVNK, a leader in stablecoin infrastructure, for up to $1.8 billion.”...By: BakerHostetler
UK FCA Seeks Views on How Its Regulation Can Helps SMEs Access Finance
The UK Financial Conduct Authority (FCA) has published a call for input seeking views on how its regulatory framework can better support small- and medium-sized enterprises (SMEs) in accessing finance. The FCA considers this part of its commitment to make sure businesses have better access to capital and its strategic priority of supporting growth. The work is intended to help the FCA design its regulatory approach, prioritise future work and complement the joint initiatives being undertaken by...By: A&O Shearman
FinCEN Imposes Record Penalty on Broker-Dealer: Compliance Lessons Going Forward
The Financial Crimes Enforcement Network (FinCEN) entered into a consent order on March 6, 2026, imposing an $80 million civil money penalty against a global broker-dealer (Broker-Dealer) – the largest Bank Secrecy Act (BSA) enforcement action ever brought against a broker-dealer. The FinCEN action arose from Broker-Dealer’s alleged willful failure to implement an effective anti-money laundering (AML) program from approximately March 2018 through June 2024....By: Holland & Knight LLP
SEC and CFTC Issue Landmark Joint Interpretation on Crypto Asset Classification
On March 17, 2026, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly issued a landmark interpretation regarding the application of the federal securities laws to certain types of crypto assets and transactions involving crypto assets....By: Jenner & Block
Federal judge rules CFPB must continue to ask Federal Reserve for funds
In a decision that delivered a blistering rejection of the Trump Administration’s CFPB plans, a federal judge has ruled that the Bureau must continue to request funds from the Federal Reserve Board....By: Ballard Spahr LLP
NY Mortgage Companies: Are You Ready For Your New Section 120 Responsibilities?
On January 6, 2026, the New York State Department of Financial Services published its new Section 120 regulations. Section 120 imposes on mortgage companies that extended 200 or more mortgage originations in New York State during the prior calendar year an obligation to meet the needs for credit services in the communities they serve....By: GeoDataVision
Fed’s Bowman plans to advance final phase of Basel III capital framework
In a March 12 speech, Fed Vice Chair for Supervision Michelle Bowman announced that the Fed will propose rules in the coming weeks to implement the final phase of Basel III in the U.S. in coordination with the OCC and the FDIC....By: Orrick, Herrington & Sutcliffe LLP
Updated: Federal District Court Vacates FinCEN Rule for Residential Real Estate Transfers
On March 19, 2026, a federal district court in Texas vacated a rule recently imposed by the Financial Crimes Enforcement Network (“FinCEN”), a division of the United States Treasury Department. See Flowers Title Companies, LLC v. Scott Bessent. The “Anti-Money Laundering Regulations for Residential Real Estate Transfers” rule, known as RRE, went into effect on March 1st. 31 C.F.R. Sec. 1031.320. RRE required transfers of residential real estate to an entity or trust that were not financed by a...By: Bowditch & Dewey
Bipartisan Senate Bill Proposes Significant Improvements To US Tax Administration
On February 26, 2026, the Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) introduced the Taxpayer Assistance and Service Act (TAS) to the Senate Floor with bipartisan support. Aimed at streamlining tax administration and improving taxpayer access to the IRS, the TAS builds on an earlier January 30, 2025 discussion draft and two recently-proposed bills in the House, the Fair and Accountable IRS Reviews (FAIR) Act and the Tax Court Improvement Act...By: Eversheds Sutherland (US) LLP
CFTC and SEC announce memorandum of understanding on regulatory harmonization
On March 11, the CFTC and SEC announced a memorandum of understanding (MOU) to guide coordination and collaboration between the agencies, with the stated goal of supporting lawful innovation, upholding market integrity, and ensuring investor and customer protection....By: Orrick, Herrington & Sutcliffe LLP
Illinois District Court Upholds Interchange Fee Restrictions
Banks and credit unions are preparing for the loss of interchange fees on Illinois debit and credit card transactions following the court’s decision in Illinois Bankers Association et al. v. Raoul, No. 24-7307 (N.D. Ill. Feb. 10, 2026), denying (in part) the industry’s request for a permanent injunction against Illinois’s Interchange Fee Protection Act (the “IFPA”)....By: Krieg DeVault
Treasury and Fed officials call for bank liquidity coverage ratio reform
On March 3, in remarks at a roundtable on bank liquidity, Treasury Under Secretary for Domestic Finance Jonathan McKernan called for significant reforms to the liquidity coverage ratio and the broader bank liquidity framework. McKernan characterized bank liquidity as “the next big-ticket item” for regulatory reform, arguing that post-crisis liquidity regulation was an “inevitable overcorrection” that has excessively limited banks’ ability to lend, noting that roughly 25 percent of large banks’...By: Orrick, Herrington & Sutcliffe LLP
FINRA Announces Updates to Enforcement Program
On March 2, FINRA’s Head of Enforcement Bill St. Louis announced important changes to FINRA’s enforcement program. Many of the changes have the potential to benefit entities and individuals involved in FINRA enforcement investigations in certain circumstances....By: Paul Hastings LLP
NCUA announces seventh round of deregulation proposals
On March 10, the NCUA announced a proposed rule aimed at streamlining its regulations on credit union records retention under 12 CFR 749, marking the seventh round of its ongoing “Deregulation Project”...By: Orrick, Herrington & Sutcliffe LLP
UK FCA Regulatory Priorities Report On Consumer Finance
The UK Financial Conduct Authority (FCA) has published its regulatory priorities report for the consumer finance sector. These reports replace the FCA's previous portfolio letters and aim to provide a clearer and more consistent articulation of regulatory expectations....By: A&O Shearman
Payroll Errors and the Domino Effect on Your 401(k) Plan
Most 401(k) problems don’t start in the plan. They start in payroll. Plan sponsors tend to think of payroll as an administrative function and the 401(k) as a separate benefits issue....By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.
The Weekly Hill Update - March 2026 #3
Below is this week’s congressional update by BakerHostetler’s Federal Policy team. We’ll continue to post in weeks when both chambers of Congress are in session....By: BakerHostetler
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