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|Brazil’s CADE Executes Cooperation Agreement with IDB and World Bank|
Eduardo Molan Gaban; Mayer Brown LLP;
March 18, 2015, previously published on March 17, 2015The Administrative Council for Economic Defense (“CADE”) has recently executed a “Memorandum of Understanding” with the World Bank Group, as well as a “Covenant for Cooperation and Sharing of Information” with the Inter-American Development Bank...
|Virtual Credit Card Payments|
Patricia S. Hofstra; Duane Morris LLP;
March 18, 2015, previously published on February 6, 2015On January 30, 2015, several healthcare organizations sent a group letter to CMS protesting the use of virtual credit cards by health plans to pay providers. In a virtual credit card payment (a nonstandard type of electronic funds transfer EFT), a health plan or its payment vendor issues single-use...
|JOBS Act - Increased Thresholds for Exchange Act Registration: SEC Proposes Rule Amendments to Implement JOBS Act Provisions That Increased Thresholds for Registration and Reporting Obligations|
Robert Buckholz, Catherine M. Clarkin, Jay Clayton, Audra D. Cohen, H. Rodgin Cohen; Sullivan & Cromwell LLP;
March 18, 2015, previously published on December 23, 2014On December 18, 2014, the SEC issued a release proposing amendments to various Exchange Act rules to reflect the new, higher thresholds for Exchange Act registration by all issuers, and for termination of registration and suspension of reporting by banks and bank holding companies, that were set...
|The Quebec Court of Appeal Rules that Information Exchanged Between Financial Institutions and the OSFI May be Disclosed to a Plaintiff in a Litigious Context|
Patrick Plante; Borden Ladner Gervais LLP;
March 13, 2015, previously published on February 2, 2015The Quebec Court of Appeal, in a recent 2-to-1 decision, has upheld a judgment from the Superior Court forcing Manulife Financial to disclose a number of confidential documents exchanged between the insurance company and the Office of the Superintendent of Financial Institutions ("OSFI")....
|Federal Reserve Bank of New York and Student Loans|
David Head; Weltman, Weinberg & Reis Co., L.P.A.;
March 13, 2015, previously published on February 24, 2015If you enjoy pie charts, line graphs, bar graphs, and even histograms, like I do, then the Federal Reserve Bank of New York did us a favor last week with its 3 part student loan series in its blog, Liberty Street Economics. The continuous drumbeat from the press can be numbing. However, data...
|Pleading Requirements for Illinois Mortgage Foreclosure Complaints Altered|
Casey Hicks; Weltman, Weinberg & Reis Co., L.P.A.;
March 13, 2015, previously published on March 2, 2015Illinois law requires a Grace Period Notice ("GPN") to be sent to the mortgagor(s) prior to commencing an action to foreclose a mortgage secured by residential real estate. The GPN must include the date the notice was mailed, be headed in bold 14-point type "GRACE PERIOD NOTICE"...
|Prevailing-party Agents Entitled to Attorney's Fees|
Bryan E. Mouber; Baker Sterchi Cowden & Rice, L.L.C.;
March 13, 2015, previously published on February 9, 2015In Curo Enterprises, LLC v. Dunes Residential Services, Inc., No. 111,191, 2015 Kan. App. LEXIS 1 (Kan.App. January 2, 2015), Curo, in its capacity as DPW’s agent, brought suit against Dunes, in its capacity as DPW’s property manager, in order to terminate DPW’s agreement with...
|The CFPB to Regulate Payday Lending Practices|
Courtney Blowers; Weltman, Weinberg & Reis Co., L.P.A.;
March 13, 2015, previously published on February 24, 2015Payday lenders and possibly other short-term loan lenders will soon be subject to federal regulations. Although the Consumer Financial Protection Bureau (“CFPB”) has not released its proposal yet, it is no secret that one is in the works.
|Recovery Framework for Central Counterparties Proposed by ISDA |
Carol E. Derk, Sienne Lam; Borden Ladner Gervais LLP;
March 13, 2015, previously published on February 5, 2015Central counterparties (CCPs) are a fundamental part of global financial markets, facilitating most over-the-counter (OTC) derivatives transaction flow and risk positions. If a CCP shuts down, it may not be able to continue its important services without the help of resolution authorities or public...
|Update On Amendments To The Personal Property Security Act (Ontario)|
Shane B. Pearlman; Borden Ladner Gervais LLP;
March 13, 2015, previously published on January 13, 2015The Government of Ontario has proposed three significant amendments to the Personal Property Security Act (Ontario) (the “PPSA”) in recent years which have not yet been brought into force. The changes are: (1) to perfection of security interests in cash collateral; (2) to the conflict...