Key Points The GAO's report on the CFPB reorganization confirms that mass workforce reductions, dismissed enforcement actions and a congressionally slashed budget cap have fundamentally reshaped federal consumer finance supervision. The pending en banc D.C. Circuit decision in National Treasury Employees Union v. Vought will likely determine whether the CFPB's proposed 88% reduction in force proceeds. Financial services providers should prepare for fewer federal CFPB enforcement actions offset by aggressive multistate regulatory oversight and a rise in private consumer finance litigation invoking CFPB-developed legal theories. The Government Accountability...

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As the transposition deadline of 7 June 2026 looms closer, EU member states remain at vastly different stages of implementing the EU Pay Transparency Directive. Quick Hits EU member states Estonia, Malta, Lithuania, and Slovakia have released recent updates on their respective implementation of the EU Pay Transparency Directive. Delays are now expected for Estonia; meanwhile, Malta, Slovakia, and Lithuania are still on track to meet the 7 June 2026 deadline. The European Commission has previously stated that the date for implementation remains...

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On April 10, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) jointly issued a notice of proposed rulemaking (NPRM) setting out their view of how sanctions, anti-money laundering and countering the financing of terrorism (AML/CFT) compliance requirements should apply to permitted payment stablecoin issuers (PPSIs) under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The agencies also issued an accompanying fact sheet. This NPRM follows Treasury’s earlier proposal on principles for acceptable state stablecoin regulatory...

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Lawyers, both in-house and in private practice are making growing use of generative AI in the delivery of legal services.  This had led to the creation of a whole new category of documents, in the form of prompts and AI outputs.  Such documents, as with any others, may be subject to disclosure in legal proceedings, unless protected by privilege. Recent rulings on both sides of the Atlantic have highlighted the growing tensions between the use of generative AI tools and...

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For European investors eyeing the U.S. market with an acquisition, the “Stock vs. Assets” debate is more than just a legal technicality; it dictates your future liability profile and tax efficiency. Whether you acquire shares of stock directly through a European legal entity (“European Entity”) or utilize a Delaware “Newco” to buy assets, your choice should align with your long-term risk tolerance and exit strategy. In our new alert, we outline two different acquisition scenarios, highlighting the benefits, opportunities, and...

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European Commission adopts RTS under EU Ratings Regulation The European Commission adopted two draft Delegated Regulations supplementing the ESG Ratings Regulation. The European Securities and Markets Authority (ESMA) consulted on the draft RTS in May 2025. Draft Delegated Regulation with regard to RTS specifying the measures and safeguards to be implemented by ESG rating providers to separate their ESG rating activities from their other activities Draft Delegated Regulation with regard to RTS specifying the elements of ESG rating products to...

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Price discovery emerges as AI and geopolitical volatility cloud the inflation and rate outlook.  The article in brief: •  Heightened volatility in early 2026, driven by AI-related disruption concerns and geopolitical developments, pushed credit markets back into price discovery mode. •  Primary market activity slowed late in the quarter, while secondary spreads widened, particularly for technology and software-exposed credits. •  Despite near-term uncertainty, lender demand remains strong, and the market backdrop continues to favor high-quality borrowers, with higher risk premiums for AI-, tariff-,...

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Innovation is Easy. Approval is Not Digital assets are having a moment. But for ETF sponsors, in addition to the underlying product innovation, there is still the need to concurrently navigate the regulatory gauntlet of custody, valuation, market integrity and compliance. Formerly fringe, digital assets are firmly implanted in the product pipeline. Even with investor demand rising, many digital asset ETF concepts don’t fail in design – they stall in regulatory review. We’ve worked alongside sponsors on first-of-their-kind cryptocurrency and blockchain-based...

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