Welcome to Goodwin's Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking.
In this issue
- CFPB Announces Potential Relief From Registration Requirements for Small Loan Providers
- FinCEN Renews Geographic Targeting Orders Involving Certain Real Estate Transactions
- FDIC Makes Temporary Electronic Communication Guidance Permanent
1 CFPB Announces Potential Relief From Registration Requirements for Small Loan Providers
On April 11, the Consumer Financial Protection Bureau (CFPB) announced that "it will not prioritize enforcement or supervision actions with regard to entities that do not satisfy future deadlines" under 12 CFR part 1092 - Registry of Nonbank Covered Persons (Nonbank Registration), enacted to create a central public repository for information regarding public agency and court orders imposed upon nonbank covered persons. Instead, the CFPB expressed its intent to focus its enforcement and supervision activities on "pressing threats to consumers" and to potentially issue a notice of proposed rulemaking to rescind the regulation or narrow its scope.
2 FinCEN Renews Geographic Targeting Orders Involving Certain Real Estate Transactions
On April 14, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders (GTOs), requiring US title insurance companies to report the beneficial owners behind legal entities involved in certain non-financed residential real estate purchases. Title insurers must verify and report identifying information for individuals who own 25% or more of a purchasing legal entity, even if similar data has been reported elsewhere. The renewed orders are effective from April 15 through October 9, 2025 and apply to transactions of $300,000 or more (or $50,000 in Baltimore) conducted without traditional financing and involving payment in part with cash, checks, wires, or virtual currency. Covered jurisdictions include major metropolitan areas across 14 states and the District of Columbia. Covered businesses must retain records for five years and may rely on third-party information in fulfilling compliance requirements. FinCEN emphasized that reporting obligations under the GTOs are distinct from those under the Corporate Transparency Act.
3FDIC Makes Temporary Electronic Communication Guidance Permanent
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New Insight: Luxembourg Takes Legislative Step to Implement the Digital Services Act
Luxembourg has adopted the law of April 4th, marking a significant step toward the national implementation of Regulation (EU) 2022/2065 on a Single Market for Digital Services (the Digital Services Act, or DSA). The DSA is a cornerstone of the European Union's digital strategy and introduces a comprehensive legal framework for digital service providers, aimed at fostering a safer, more transparent online environment across the EU. This development marks an important milestone in the EU-wide rollout of a unified framework for digital service providers. To read the full article, click here.
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