Bank Law Monitor
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Article 12 – Perfection of Security Interests in Controllable Electronic Records
It is well established how to perfect a security interest on general intangibles under Article 9 of the Uniform Commercial Code: filing a financing statement. But is there a better way for a secured party who wants to stay in first position on assets...
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New Reporting Requirements for Deposit Interest Paid to Residents of Chile
On September 28, 2021, the IRS released an advance version of Revenue Procedure 2021-32, updating previous guidance with respect to information reporting requirements applicable to residents of certain countries. Under previous guidance, the United S...
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SEC Adopts New Amendments to Exempt Offering Rules
The Securities and Exchange Commission (SEC) has adopted a series of amendments to rules under the Securities Act of 1933 (Securities Act) applicable to offerings exempt from public registration. The amendments will become effective 60 days after the...
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Banking Regulators Encourage Lenders to Work with Borrowers Impacted by COVID-19
Mar 23, 2020
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Federal banking regulators took a bold, first step this past Sunday, announcing Interagency Guidance ("the Guidance") to encourage lenders to work with borrowers impacted by the COVID-19 outbreak.[1] The Guidance specifically permits lenders to enter...
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FinCEN Reverses Course on Beneficial Ownership Requirements in Connection with Loan Renewals and Modifications
It can be hard for regulatory agencies to admit when they’ve made a mistake. But that’s exactly what FinCEN did last week when it announced that certain loan renewals and modifications[1] would not trigger its beneficial ownership due diligence rule...
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The STATES Act—A Solution to the Cannabis Banking Problem on the Horizon?
By Danielle Hunt, Kalin Bornemann, Olivia Grabacki, and Jessica Roberts
As we previously discussed, financial institutions that offer financial services to the cannabis industry have been operating in a state of uncertainty in the wake of the rescis...
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