Venable attorneys produce periodic alerts and newsletters covering a variety of topics and practice areas. For your convenience, we have assembled below a collection of the latest alerts and newsletters from October 2015.
Leveling the Playing Field or Protecting Its Turf? SEC Proposes Amendments to Rules Governing Administrative Proceedings
Facing mounting legal challenges to its use of administrative proceedings on a wide variety of enforcement matters, the SEC recently announced proposed amendments to rules governing its administrative proceedings. The amendments address nearly every stage of the administrative hearing process, write Venable attorneys Michael J. Rivera and Joanna P. Breslow Boyd, with the most notable changes proposed for the rules governing pre-hearing discovery, the duration of proceedings, and electronic filing and service. While SEC Chair Mary Jo White couched the amendments as designed to "modernize" administrative proceedings, this move is widely perceived as an attempt to assuage criticism directed at the Commission's recent increased use of this forum.
Continue reading this client alert to learn about the proposed amendments as well court challenges to the SEC's administrative proceedings.
Employers' ACA Reporting Deadlines Fast Approaching
Venable attorneys Juliana Reno and Thora A. Johnson write that employers with ACA reporting obligations have only 3 months left—the first deadlines hit on February 1, 2016. One reporting obligation belongs to large employers. Another belongs to employers that sponsor self-funded plans that constitute minimum essential coverage.
Click here for a review of the reporting requirements and their deadlines.
CFPB Releases Final HMDA Rule
Less than two weeks after the effective date for the TILA-RESPA Integrated Disclosures, the Consumer Financial Protection Bureau (CFPB) has unleashed another major rulemaking on the mortgage industry: its long-awaited final rule amending and expanding reporting requirements under Regulation C and the Home Mortgage Disclosure Act (HMDA). The 797-page final rule, released on October 15, 2015, revises and in many ways expands the breadth and scope of HMDA data collection requirements—which, write Venable attorneys Allyson B. Baker, Andy Arculin, and Peter S. Frechette, includes the addition of roughly 25 new data fields and the modification of an additional 12 data fields.
Continue reading to learn about important changes to HMDA and Regulation C reporting requirements.
Upcoming Events:
Webinar: State of Financing Markets for Private Equity Portfolio Companies
November 16, 2015 | 12:00 – 1:00 p.m. ET
Debt financing plays a critical role in the development of private equity-owned companies, particularly in the middle market, and the industry continues to evolve as it relates to new structures and terms. Please join Venable LLP, Churchill Asset Management, SPP Capital Partners and Enhanced Capital for an in-depth and nuanced discussion on the state of financing markets for private equity.
Click here for more information and to register.
Day 44 After The TILA-RESPA Integrated Disclosure Rule – Washington, DC
November 16, 2015 | 5:45 – 9:00 p.m. ET
The TILA-RESPA Integrated Disclosure Rule (TRID) took effect on October 3, 2015. TRID is not only complicated and technical; it affects all aspects of a mortgage transaction from application to closing. Now that we are 44 days "AT" or "After TRID," with the first wave of closings drawing to completion, this symposium will examine what we have learned so far, as well as the biggest obstacles that remain. Then the symposium will shift gears to look into 2016 and discuss strategies for examination preparation, and what to expect from CFPB and other regulators. Finally, the symposium will look at "What's Next" for the CFPB, including implementation of the new Home Mortgage Disclosure Act (HMDA) rule and additional rulemakings calendared for 2016.
Click here for more information and to register.
Webinar: Minimizing Legal and Compliance Risk for Credit Furnishers
November 18, 2015 | 2:00 – 3:00 p.m. ET
Furnishing data to the credit reporting agencies? Recent Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) activity reflect an increase in scrutiny of companies that supply or "furnish" information to consumer reporting agencies (CRAs) as required by the Fair Credit Reporting Act (FCRA). Data furnishers including merchants, debt collectors, and lenders can reduce supervision and enforcement risk by avoiding the common mistakes the FTC and CFPB have identified in their recent enforcement announcements. Hear from attorneys who are in the trenches defending companies in CFPB and FTC investigations and CFPB examinations.