On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the “CIP Proposal”) that would apply customer identification program obligations
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Supreme Court Preemption Ruling Could Create Uncertainty and Burden for National Banks
On May 30, the Supreme Court issued its opinion in Cantero v. Bank of America, N.A., in which the Court was set to decide whether national banks must comply with state interest-on-escrow laws (and by extension, certain other state
Sounding Board: Shareholder Engagement
In this MB Sounding Board MicroTalk, Larry Cunningham talks to Henrique Canarim, Vice President, Senior Assistant General Counsel, and Assistant Corporate Secretary at Leidos, about the rising trend of shareholder engagement by directors, its advantages, and preparing directors for
Frequently Asked Questions for FINRA Member Firms on AI Use in Public Communications
Several days ago, FINRA released guidance updating its Frequently Asked Questions relating to Rule 2210 on Advertising and Public Communications to address Artificial Intelligence. This follows after FINRA has consistently been noting that the use of AI and AI tools
SEC’s Upcoming Investor Advisory Committee Meeting: Finfluencers and AI
The Securities and Exchange Commission announced an upcoming meeting of its Investor Advisory Committee, which will be held on June 6, 2024. The agenda includes a number of interesting topics.
The Committee will consider and address the impact of “finfluencers.”
‘Sexism in the City’: UK Government will not ban NDAs in sexual harassment cases
The UK Government has responded to the recent ‘Sexism in the City’ report by the House of Commons Treasury Select Committee (the “Report”). Among various recommendations in the Report was an outright ban on the use of non-disclosure agreements (“NDAs”)
ESMA’s Final Report on the 2023 Common Supervisory Action and Mystery Shopping Exercise on marketing
The European Securities and Markets Authority (ESMA), published a combined report on its 2023 Common Supervisory Action (CSA) and the accompanying Mystery Shopping Exercise (MSE) on marketing disclosure rules under MiFID II. ESMA, together with the National Competent Authorities (NCAs),
Private Transfer Pricing Disputes
In most transfer pricing disputes, the taxpayer squares off with the IRS or some other taxing authority, and the issue is the amount of tax due. But, in some cases, a company’s transfer pricing policies can lead to disputes between
At A Glance: Covered Bonds in 2023
Following the financial sector disruptions in 2023, financial institutions turned first to covered bonds for funding and the covered bond market demonstrated its resilience. Just as the covered bond market remained available through the financial crisis in 2008 through 2010,
CFPB Interpretive Rule Exposes Some BNPL Programs to Credit Card Requirements
On May 22, the Consumer Financial Protection Bureau (“CFPB”) issued an interpretive rule purportedly clarifying the breadth of the term “credit card” for Truth in Lending Act (“TILA”)/Regulation Z purposes in the buy-now/pay-later (“BNPL”) context (the “Interpretive Rule”). The clarification