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To Z or Not to Z? CFPB Clarifies the Regulation Z Treatment of Certain Earned Wage Access Products
The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion (the 2025 Opinion), effective 23 December 2025, on whether earned wage access (EWA) products constitute “credit” under Regulation Z of the Truth in Lending Act, and whether Regulation Z’s definition of “finance charge”...By: K&L Gates LLP
Value for Money: Better Retirement Outcomes and Greater Transparency – Further Consultation on New Framework for DC Pension Schemes
The Financial Conduct Authority (FCA) and the Pensions Regulator (TPR) are consulting further on the new value for money (VFM) framework for DC pension schemes. The consultation is intended to serve as......By: Mayer Brown
Federal Reserve Board Seeks Comment on "Skinny" Master Account/Payment Account Prototype
The Federal Reserve Board (the Board) has issued a Request for Information and Comment (RFI) on the development of a special purpose Reserve Bank account prototype, being referred to colloquially as a "skinny master account" or "Payment Account," which would enable eligible institutions to directly facilitate clearing and settlement activities for their own payment transactions with the Federal Reserve Banks. Comments on the proposal are due February 6, 2026....By: Stinson LLP
Staff Report from the Office of the Advocate for Small Business Capital Formation: Part II
IPOs and Small Public Companies As we noted in our prior post, the Office of the Advocate for Small Business Capital Formation recently issued its Staff Report for fiscal year 2025, which provides information on the Office’s activities. We discussed the Report’s findings with respect to reliance on exempt offerings as well as pooled funds. In this post, we focus on the Report’s analysis with respect to initial public offerings and small public companies....By: Mayer Brown Free Writings + Perspectives
Italian Legislative Decree implementing CCD2
Following a public consultation issued by the Italian Ministry of Economy and Finance, on 9 January 2026 the Italian Legislative Decree No. 212 of 31 December 2025 containing the implementation of Directive (EU) 2023/2225 on credit agreements for consumers (“CCD2”) and repealing Directive 2008/48/EC (“CCD1”) was published in the Official Gazette (“CCD2 Italian Decree”)....By: Hogan Lovells
Taking a Closer Look at the COINS Act
The Fiscal Year 2026 National Defense Authorization Act, signed into law on December 18, 2025, includes the Comprehensive Outbound Investment National Security Act of 2025 (COINS Act), which establishes a statutory framework to prohibit or require notification of certain outbound investments by U.S. persons in technology sectors deemed sensitive to U.S. national security....By: Pillsbury - Global Trade & Sanctions Law
SEC Clarifies Custody of Crypto Assets by Broker-Dealers
The United States Securities and Exchange Commission (SEC) on Dec. 17 issued a statement noting its position on the applicability of Rule 15c3-3 regarding broker-dealers that hold crypto asset securities, including such things as debt securities, or tokenized equity, on behalf of customers....By: Goldberg Segalla
CFPB Submits to Court Order, Seeks New Funding
On January 9, 2026, the Consumer Financial Protection Bureau (CFPB) requested $145 million in new funding from the Federal Reserve....By: Cooley LLP
New Short Position Reporting Requirements: Initial Filings Due February 17, 2026
Institutional investment managers, including venture and private equity funds and other institutional investors, that engage in the short selling of equity securities should be mindful of the Securities and Exchange Commission’s new short position reporting requirements under Rule 13f-2....By: Cooley LLP
FINRA Proposes Rule Changes Designed to Help Member Firms Combat Financial Exploitation of Seniors and Other Investors
On January 8, 2026, FINRA issued Regulatory Notice 26-02 announcing proposals for a new rule and revisions to two existing rules. FINRA seeks to revise Rule 4512’s provisions regarding trusted contact persons, to increase Rule 2165’s maximum hold period, and to introduce Rule 2166 that allows for a “speed bump” hold when a member firm suspects fraud of any investor regardless of age or capacity....By: Bressler, Amery & Ross, P.C.
ALC’s 2026 EB-5 Market Outlook: Top 10 EB-5 Trends You Can’t Ignore
The EB-5 market is set for another milestone year in 2026, and the American Lending Center (ALC) is continuing our focus on Immigrant First Investing....By: American Lending Center
Distressed Debt Legal Insights - STG Logistics' LMT Litigation
Welcome to Distressed Debt Legal Insights, Ropes & Gray’s source of timely insights for professionals navigating the complex world of liability management and special situations finance. In this issue we discuss the first major decision of 2026: STG Logistics....By: Ropes & Gray LLP
FINRA Acceleration of Arbitration Proceedings forQualifying Parties Update
Introduction In August 2025, the Financial Industry Regulatory Authority Dispute Resolution Services (“FINRA DRS”) amended certain Rules related to the length of processing arbitration proceedings....By: Bressler, Amery & Ross, P.C.
Asia private capital: fourth-quarter data and trends
Asia private capital dealmaking defies global uncertainties - We started 2025 by predicting that, after a subdued first quarter, data suggested an imminent uptick in the M&A and exit markets. That optimism proved to be short lived, as 'Liberation Day' tariffs drove uncertainty and reined in dealmaking activity....By: Herbert Smith Freehills Kramer
Treasury Targets Fraud: Heightened Bank Compliance Risks
On January 9, 2026, U.S. Treasury Secretary Scott Bessent announced a series of new federal actions focused on schemes to defraud federal aid programs. Treasury’s announcement follows a series of high-profile investigations involving alleged fraud tied to federally funded programs, such as the Feeding Our Future scheme to defraud the Federal Child Nutrition Program in Minnesota....By: Ballard Spahr LLP
Why Your 401(k) Plan May Want to Retain an Investment Manager
The recent decision in Wanek v. Russell Investments demonstrates how retaining a 3(38) investment manager--selected through a well-documented process--may help limit an employer’s liability under its 401(k) plan....By: Bradley Arant Boult Cummings LLP
Healthcare & Life Sciences Private Equity Deal Tracker: Veritas to Acquire GHX
Veritas Capital announced one of its affiliates will acquire a majority stake in Global Healthcare Exchange (GHX). GHX, founded in 2000 and based in Louisville, Colorado, is a supply chain software platform....By: McGuireWoods LLP
[Webinar] The U.S. Outbound Investment Rule: Impacts on Global Business Strategy - January 28th, 9:00 am - 10:00 am EST
The U.S Department of the Treasury implemented the Final Rules governing outbound investment (the “Rule”) on January 2, 2025. As part of the National Defense Authorization Act of 2026, Congress enacted the Comprehensive Outbound Investment National Security Act of 2025 (the “Act”). The Rule remains effective pending issuance of new regulations mandated by the Act, which expands both the technologies impacted and the countries to which these restrictions apply....By: Blank Rome LLP
U.S. SEC Staff Issues Long-Awaited Crypto Asset Securities Guidance for Carrying Broker-Dealers
Overview of the SEC Staff Guidance- On December 17, 2025, the staff of the SEC’s Division of Trading and Markets (the, “Staff”) issued a statement, expressly limited in scope, regarding how broker-dealers that carry customer securities (“Carrying Broker-Dealers”) may evidence physical possession (“possession”) of crypto asset securities for purposes of Rule 15c3-3(b)(1) of the Securities Exchange Act of 1934 (the Customer Protection Rule)....By: Morrison & Foerster LLP
Day 2 Notes from the 44th Annual J.P. Morgan Healthcare Conference
J.P. Morgan continues to surprise us at lunch, with the Mayor of San Francisco sharing on Monday an update on recent improvements in the city. Then on Tuesday at the Grand Ballroom lunch, it was the first episode of my favorite new sit-com “Everyone but Abe…”...By: Sheppard Mullin Richter & Hampton LLP
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