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Stablecoin Interest, Yield, and Rewards: OCC Proposes Sweeping Regulations Under the GENIUS Act
The OCC issued a notice of proposed rulemaking (NPRM) last week to implement the GENIUS Act, enacted on July 18, 2025. The NPRM is significant, as it creates a new Part 15 to the OCC’s regulations addressing payment stablecoins, including permissible activities, reserves, capital requirements, application processes, disclosures, redemptions, and more. It requests public consideration and input on more than 200 questions, set out over nearly 300 pages of commentary....By: Perkins Coie
Digital Assets and Cryptocurrencies Developments: ABA White Paper
The American Bar Association Business Law Section published a robust and in-depth white paper in September 2025 on “Digital and Digitized Assets: Federal and State Jurisdictional Issues,” providing a comprehensive explanation of key federal, state and international laws governing the creation, offer, uses and trading of digital assets....By: Paul Hastings LLP
ESMA and EBA Consult On Revised Suitability Assessment Guidelines For Banks And Investment Firms
The European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) have launched a joint consultation on draft revised guidelines on the suitability assessments of members of the management body and key function holders at banks and investment firms. This follows the earlier version published in 2021. The proposed revisions form part of a broader suitability package aimed at harmonising suitability assessments and strengthening supervisory convergence across the EU....By: A&O Shearman
Dance Like No One is Watching, Text Like Your Words Will Be Published on the Front Page: The Importance of Internal Compliance with FINRA and Text Message Production
Earlier this month, Benjamin Edwards, a broker-dealer firm, agreed to a censure and to pay a $750,000 fine for failing to properly supervise and preserve its employees’ business-related text messages....By: Benesch
New York City Finalizes Expanded Debt Collection Rules Covering Original Creditors and Third-Party Collectors
The New York City Department of Consumer and Worker Protection (NYC DCWP) has adopted a comprehensive set of amendments to its debt collection rules, effective September 1, 2026. The final rule clarifies that New York City’s consumer protection framework applies not only to traditional third‑party debt collectors and debt buyers, but also to original creditors once they engage in defined “debt collection procedures.”...By: Troutman Pepper Locke
The Rise of Strategic Joint Ventures and Alternative Structures in Data Centre Investment
The UK data centre sector has evolved into one of the most competitive and capital-intensive asset classes across global real estate and infrastructure. Delivering a single hyperscale facility, often requiring more than half a billion pounds of investment—alongside intense competition for powered land and lengthy grid connection timelines, has made the traditional single-developer financing model unsustainable....By: BCLP
Sizing the Potential of a New Market or Product
New markets and new products, or services provide the engine of growth for many companies. Faced with sluggish demand in existing markets, the need for continued innovation, and investors who require ongoing growth, companies find themselves entering new markets,...By: IMS Legal Strategies
UK FCA Consults On Approach To Implementing Remedies From Credit Information Market Study
The UK Financial Conduct Authority (FCA) has published consultation paper CP26/7 outlining its proposed approach to implementing the FCA led remedies arising from the credit information market study. The study introduced a package of measures aimed at improving the credit information market, including proposed new FCA rules and guidance, reforms to industry governance arrangements and other industry-led remedies. A new Credit Information Governance Body is now in place and industry participants...By: A&O Shearman
CRD VI Consequences For M&A Transactions
CRD VI (Directive (EU) 2024/1619) introduces a new harmonized regime requiring banks to notify competent authorities of, and in some cases receive prior approval for, M&A transactions generally. This expands on the current regime which relates solely to qualifying holdings in credit institutions, although some EU Member States had previously already implemented similar rules on a national level. CRD VI should have been transposed by Member States by January 10, 2026 and the M&A provisions should...By: A&O Shearman
UK FCA Confirms Reporting Window On The CCR009 Return For Relevant Ancillary Credit Firms
The UK Financial Conduct Authority (FCA) has published an updated webpage on the CCR009 return for relevant ancillary credit firms. The update confirms that, for data covering 1 January 2025 to 31 December 2025, the reporting window will open on 2 March....By: A&O Shearman
The Payments Newsletter including Digital Assets & Blockchain, February 2026
Key developments of interest over the last month include: the UK government publishing a Payments Forward Plan setting out a regulatory roadmap for the payments sector over the next three years; the German Federal Ministries of Finance and Justice launching an evaluation of the Electronic Securities Act; the UAE approving its first USD‑backed stablecoin under the Payment Token Services Regulation; Hong Kong preparing to issue its first stablecoin issuer licences in March 2026; and the U.S. SEC...By: Hogan Lovells
FinCEN’s New Residential Real Estate Reporting Rule
The new Residential Real Estate Reporting Rule (“RRE Rule”) requires professionals involved with non-financed transfers of residential real estate to legal entities or trusts to submit reports to the Financial Crimes Enforcement Network (“FinCEN”)....By: Hone Maxwell
Canada Eases Comprehensive Sanctions Against Syria
On February 18, 2026, the Government of Canada announced significant amendments to the Special Economic Measures (Syria) Regulations (Syria Regulations), marking a substantial shift in Canada’s sanctions framework applicable to Syria....By: Blake, Cassels & Graydon LLP
Bitcoin’s Volatility Should Give Plan Sponsors Serious Pause
Every few years, a new investment trend arrives with the same promise: higher returns, innovation, and the fear of being left behind. Bitcoin is the latest example, and while it may have a place in speculative portfolios, its volatility should give every 401(k) plan sponsor serious pause....By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.
Stablecoins: An Emerging Consideration for Merchants
As 2026 gets under way, the payments ecosystem continues to innovate and evolve. Payments companies face business pressure from numerous directions. Consumers expect fast, low-cost, and borderless payments, while merchants seek solutions that reduce friction and enhance financial control....By: Venable LLP
A Primer on Canadian Sanctions Legislation - March 2026
Canada, like other major jurisdictions, has a broad range of economic and financial sanctions targeting foreign states and their nationals, as well as various terrorist organizations....By: Blake, Cassels & Graydon LLP
Why Changing Payroll Providers Is a 401(k) Event
Plan sponsors treat changing payroll providers the way homeowners treat replacing a dishwasher. Unplug the old one, slide in the new model, and suddenly everything runs better. In the retirementplan world, it’s nothing like that. Switching payroll is closer to rewiring your house while the lights are still on and the kids are microwaving popcorn. Payroll is not an accessory to the 401(k) plan— it is the nervous system. Every deferral, match calculation, eligibility date, and compensation...By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.
Private Credit’s Moment of Truth: Why Defaults Create an Investigative Problem, Not Just a Financial One
Private credit firms are exceptionally good at what they were built to do: source, underwrite, and deploy capital with speed and precision. That capability drove the asset class from a niche strategy to the center of the financial system in under a decade – a remarkable achievement by any measure....By: Guidepost Solutions LLC
[Audio] Disparate Impact
President Trump’s Executive Order 14281 may narrow disparate impact liability, but because the law remains unsettled, lenders should still use disparate impact analysis as a practical risk-management tool to spot potential discrimination and show good-faith compliance....By: GeoDataVision
Risk and opportunity as digital assets gain ground
As business models shift and regulations adapt, boards will need to understand the opportunities and risks posed by the use of digital assets. Building on the blockchain technology that enables Bitcoin and other cryptocurrencies, financial technology firms are piloting and deploying more mainstream uses for a broad array of digital assets, setting into motion a fundamental reshaping of payment networks, financial products, asset markets, and more....By: KPMG Board Leadership Center (BLC)
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