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Regulatory Developments

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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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Oregon Presses Pause on Foreclosures, Payment Defaults, and Evictions
In an effort to provide relief to homeowners, businesses, landlords, and tenants affected by COVID-19, Governor Brown signed two bills that impose significant limitations on lenders and landlords. Under HB 4204, lenders cannot foreclose on loans secu...
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“First Come, First Served:” SBA Issues Critical Guidance for Payroll Protection Program Loans
The Small Business Administration (SBA) has issued an Interim Final Rule controlling how $349 billion in short-term business loans under the CARES Act will be allocated. While the SBA is seeking comments from the public, the rule is effective immedia...
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Banking Regulators Encourage Lenders to Work with Borrowers Impacted by COVID-19
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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