The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) requires lenders on all government-backed loans to provide forbearance agreements on residential loan payments for a period of 180 days to any borrower that requests relief and affirms they are…
On October 15, 2020, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) released its Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity (Supplemental Advisory). The last time FinCEN provided guidance on identifying trafficking…
By: Elena F. Mitchell and Frank Schall.
The United Kingdom Home Office has released guidance to companies that are required to make a public statement about human trafficking risks and prevention measures under the U.K. Modern Slavery Act of 2015. Organizations are to address the emerging risks…
By: Elena F. Mitchell and Frank Schall.
By Kristina Whittaker and Ed O’Keefe. For the last three weeks or so, the federal and state banking agencies, collectively and individually, have, with increasing urgency, called on financial institutions to meet the financial needs of customers impacted by the COVID-19. Congress…
The shuttered storefronts and grounded airplanes that by now have become an all too familiar image of the COVID-19 pandemic are quickly creating a ripple effect through the U.S. economy. As unemployment rises and Americans struggle to pay their bills,…
By: Elena F. Mitchell and Frank Schall. Further implementing the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA“), the U.S. Department of the Treasury recently published a proposed rule to establish filing fees for parties filing voluntary notices of…
By Kate Wellman and Neil Bloomfield. As COVID-19 continues to spread globally, U.S. financial services regulators have released guidance to their supervised institutions to encourage proactive planning for what may be months of sustained impact to business infrastructure and the…
The transition away from LIBOR was born from the financial crisis. For years regulators have been pushing for an alternative to the dominant market benchmark. The underlying market was illiquid. The rate was set by opinion, not transactions. It was…