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How Should Entities Prepare for California’s Digital Financial Assets Law Licensing Requirement?

On March 18, 2026, the Nationwide Multistate Licensing System (NMLS) began accepting applications for a brand new license created by California’s Digital Financial Assets Law (DFAL), which was signed into law in 2023. Unless exempt, entities wishing to continue engaging in digital financial asset business activity in California must submit an application by July 1, 2026....By: Hinshaw & Culbertson - Consumer Crossroads

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The GENIUS Act Arrives and The OCC Is Set To Act

The Office of the Comptroller of the Currency (OCC) dropped a notice of proposed rulemaking to implement the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins) on Feb. 25. The OCC proposes requirements for stablecoin reserves, redemption and risk management, in addition to licensing and capitalization requirements for permitted payment stablecoin issuers....By: Dinsmore & Shohl LLP

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Hands Off the 401(k): Why Using Retirement Money for Home Down Payments Is a Terrible Idea

Every few years, someone in Washington rediscovers the 401(k) and decides it should be used for something other than retirement....By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.

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CFTC and Division of Market Oversight Issue Two Releases on Prediction Markets and Event Contracts

Prediction markets remain front-and-center at the Commodity Futures Trading Commission (CFTC or Commission). So far in March the CFTC has issued an advance notice of proposed rulemaking and staff of its Division of Market Oversight have issued an advisory, both providing first looks at how the current administration intends to regulate event contracts and prediction markets. They represent both a stark departure from the previous administration’s policies and a focus on issues that have emerged...By: Morgan Lewis

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BoE Speech On Reforming Cross‑Border Payments

The Bank of England (BoE) has published a speech delivered by Andrew Bailey, Governor of the BoE and Chair of the Financial Stability Board (FSB) at the FSB Payments Summit on reforming cross‑border payments. Mr Bailey welcomes progress under the G20 cross‑border payments roadmap but stresses that implementation now needs to accelerate to meet the G20's 2027 targets....By: A&O Shearman

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A question of timing: The applicable test date in leveraged finance

An inability to satisfy ratio or incurrence-based tests in leveraged finance loan agreements can lead to a borrower group being unable to draw debt it has paid for, or complete transactions it has legally committed to. Conversely, those same financial tests provide important guardrails for lenders. It is not surprising then that exactly when those tests must be satisfied is closely scrutinised by sponsors with a view to obtaining maximum flexibility for their portfolio businesses....By: Hogan Lovells

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Navigating the Recent Ban on Foreign Ownership for SBA Loans

Earlier this month, the U.S. Small Business Administration (SBA) banned foreign nationals, non‑citizens, and lawful permanent residents whose principal residence was outside of the U.S. from owning any interest in a small business applicant of a SBA‑guaranteed small business loan under the 7(a) and 504 programs. Effective April 1, 2026, that ban will expand to the Surety Bond (Procedural Notice 5000-877134) and Microloan (Procedural Notice 5000-877232) programs. Below, PilieroMazza highlights...By: PilieroMazza PLLC

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California Suspends Venture Capital Diversity Reporting Requirements Pending New Rulemaking

The California Department of Financial Protection and Innovation (DFPI) announced it is suspending the implementation and enforcement of the Fair Investment Practices by Venture Capital Companies Act (FIPVCC) in response to feedback and comments from various stakeholders, including Orrick, Herrington & Sutcliffe LLP. As a result, the DFPI will not require covered entities to meet the previously established registration and reporting deadline originally set for April 1, 2026....By: Orrick, Herrington & Sutcliffe LLP

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Defence sector – tackling the barriers to securing finance – EU and UK

Recently we wrote about how the UK government and the European Commission have both confirmed that investment in the defence sector is not incompatible with sustainability-related rules and regulations in our briefing here, though of course the regulators have not (and would not) say that they are always compatible. Although these clarifications have been helpful and accompanied a real change in perception of defence both from the public and business, it is not a silver bullet to removing...By: Hogan Lovells

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Private Lending: Unfolding Litigation Developments and Managing Risks

With increased uncertainty in the US economy around tariffs and other federal policies, the historically high levels of commercial and government debt in the United States and other major economies, and continued volatility in the US and global stock markets, financial institutions, private capital providers and asset management firms are currently facing a significant stress test. Reports in the financial press reflect a wave of investor withdrawals hitting major funds simultaneously, firms...By: K&L Gates LLP

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OFSI Publishes Consultation Response and Updated Enforcement Guidance: Key Changes for UK Sanctions Enforcement

On January 29, 2026, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published its response to the consultation on “Improving civil enforcement processes for financial sanctions” (“Consultation Response”), confirming that OFSI intends to proceed with all proposals consulted on in July 2025, subject to limited legislative dependencies. The majority of the changes have now been operationalized through updated guidance published on February 9, 2026....By: Pillsbury - Global Trade & Sanctions Law

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An Integrated Approach to International Investment Protection

When some energy executives and their lawyers hear “investment protection” they think arbitration. They picture a panel in some neutral city, elaborate briefs and a damages award to be executed on some asset somewhere. In “An Integrated Approach to International Energy Investment Protection,” we observe that protection doesn’t begin when the dispute starts. It begins long before the investment is even made....By: Pillsbury - Global Trade & Sanctions Law

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Affordable Housing in Challenging Times: Market Update and Insights from Active Projects in Toronto and the GTA

It has long been the objective of the governments of Ontario and Toronto to look for ways to promote the development of "off market" or affordable housing in addition to the market housing units that were being delivered from 2000-2022.  Since 2022, Ontario has experienced a year-over-year downturn in condominium sales, driven by factors including rising interest rates, lost confidence and broader macroeconomic uncertainty.  This has led to a dramatic change in the housing market in Toronto with...By: Bennett Jones LLP

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Consumer Finance Regulatory Trends: Takeaways from the 2026 NMLS Conference

Regulators and industry participants gathered at the 2026 Nationwide Multistate Licensing System (NMLS) Annual Conference & Training in Orlando to discuss emerging supervisory priorities and regulatory developments affecting the consumer finance industry. Conversations throughout the conference highlighted several themes, including evolving CFPB enforcement activity, growing scrutiny of innovative consumer finance products, expanded use of supervisory technology and the implementation challenges...By: Orrick, Herrington & Sutcliffe LLP

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Implementation of California’s Diversity Reporting Law Is Suspended

Implementation of the Fair Investment Practices by Venture Capital Companies Law (FIPVCC) has been paused pending further rulemaking, according to an announcement on March 17, 2026 by the California Department of Financial Protection and Innovation (DFPI). The law would have required venture capital companies (VCs) to register with the DFPI, survey their portfolio companies regarding the demographics of the founding team members, and submit to the DFPI reports about such demographics and other...By: Morgan Lewis

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Technology Service Vendors: Cryptoasset Wallet Provider Gets Relief Benefitting Entire Digital Asset Ecosystem, Prediction Markets Too

Staff from the Market Participants Division (MPD) of the Commodity Futures Trading Commission (CFTC or Commission) issued No-Action Letter 26-09 (Letter 26-09), providing significant regulatory relief to a cryptoasset wallet technology service vendor (TSV) seeking to expand its services into CFTC-regulated derivatives. Letter 26-09 expands upon a well-established body of CFTC guidance dating back to 2002, when the Commission first began issuing interpretive letters to TSVs providing that certain...By: Katten Muchin Rosenman LLP

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Challenging EB-5 Conventional Wisdom and Assumptions: I-956F Approvals

Many Investors incorrectly believe they should only consider investing in projects with approved I-956Fs. While this has become a sacrosanct notion of how to assess the potential success of a given EB-5 project, this is based on the faulty assumption that an I-956F approval equates to project success....By: American Lending Center

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Independent Sponsor Series: Michael Kornman of Align Collaborate Discusses Unique Approach to Independent Sponsor Investments

To help businesses, investors, and deal professionals better understand the evolving independent sponsor landscape, Robert Connolly—a partner in LP’s Corporate Practice Group and leader of LP’s Independent Sponsor team—shares a series of conversations with independent sponsors, capital providers, and other professionals....By: Levenfeld Pearlstein, LLC

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[Audio] Year in Review and Look Ahead: Servicing and Collections in Flux – How States, Reg F, and Coerced Debt Laws Are Rewriting the Playbook — The Consumer Finance Podcast

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Consumer Financial Services Partners Stefanie Jackman and Nicholas O'Conner to dissect the shifting risk landscape for servicers, collectors, and debt buyers as federal scrutiny eases and state regulators surge to the forefront. As a segment of the Year in Review and Look Ahead series, the trio talks about Reg F's post-Loper Bright staying power, the explosive growth of state medical debt restrictions and FCRA preemption...By: Troutman Pepper Locke

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Rewiring Rule 5.4: Private Capital’s Opening in U.S. Legal Services

Love it or loathe it, we must admit it: private equity (PE) funding has become a driving force and lifeblood across key industries in the U.S. and globally, especially where capital intensity, fragmentation, and regulatory complexity create barriers to scale....By: DarrowEverett LLP

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