General Counsel Blog

03/19/2025

Fraud Scheme, Minimum Standards & Fund Assembly

Hello Members! Finally! March Madness is here! I am so psyched to see if the SEC stomps all over everyone in the tournament this year. Of course, I am rooting for the Gators but as long as the SEC prevails in the end, I will be pretty satisfied. (Unless it's "that" SEC team, which I will not mention by name in order to avoid email ire from those of you who support "that" team.) Despite March Madness, there is a lot going on………. so let's get to it.

03/03/2025

Bill of the Week & More

Hello Members! It's Legislative Session time. I learned today (February 28, 2025) that over 1500 bills have been filed pre-session. That's a lot of bills to look through and make sure there aren't any surprises! Several things to point out today.

02/18/2025

It’s the Most Wonderful Time of the Year!

Hello Members! January through June is my favorite time of year for so many reasons! I could, of course, start with March Madness and could mention the announcement over the weekend of the tournament #1 seeds……but I will save that for another day! Plenty of time to fill your inbox in March with that topic…. Here are two other things going on to chat about.

02/03/2025

Beyond Tater Tots: Regs, Rules & Resources

Hello Members, Welcome to February. The month of love (Valentine's Day) but lots more. February 1 was National Tater Tot Day. Who knew? February 9 is National Pizza Day, February 12 is National Hug Day and we wrap up the month on February 27 with National Chili Day. Am I scraping the barrel for things to say? Fear not. I have two pretty substantive things to relay.

01/14/2025

New Forms, Revisions & Resource

Dear Members, It's been a month since my last blog! I'm back with several things I think are of interest. First, how about those Gators (meaning the men's basketball team)!!! They are fun to watch and root for and I hope they have a great rest of the season. And March Madness is coming……so prepare yourself to block my emails for those 3 or 4 weeks if you don't want to hear my rants and raves about the tournament….. More important stuff now.

12/26/2024

Update: FinCEN Now Requiring Beneficial Ownership Information Reporting

Dear Members, Sorry to bother you in the middle of the holidays but FinCEN has changed its position on compliance with the Corporate Transparency Act. I indicated a week or so ago that compliance was on hold in light of a Texas court ruling that the law was unconstitutional.

12/12/2024

A Nice Year-End Present from FinCEN!

Hello Members, You thought you were done with these blog postings for 2024 but FinCEN has given us a present of sorts to round off the year! The Corporate Transparency Act, which requires the reporting of Beneficial Owner Information for entities, has been "put on hold" as a result of a court ruling out of Texas. THIS HAS NOTHING TO DO WITH THE GEOGRAPHIC TARGETING ORDERS OR THE NEW FINCEN RULE THAT GOES INTO EFFECT DECEMBER 1, 2025.

12/04/2024

Important Reminders: Year End Policy Remittance & DFS Administrative Surcharge

Hello Members, Jeepers. The year is almost over! I am confident that I am 100% organized for the holidays and won't forget a single thing! How about you? At least we are experiencing some cooler weather but who knows how long that will last. A few things to remind you about.

11/06/2024

Low Stress Updates

Hello Members, There's a lot going on this week so I am keeping this to fairly low stress things.

10/21/2024

ALTA ONE Highlights, A Commercial Commercial & Renewed GTO

Hello Members! Fall is here! Enjoying a couple of days here in Orlando that are oddly cool. I've been at the ALTA annual convention (called ALTA ONE), and it has been a great 3-4 days. Even an old cynic like me gets energized and inspired by some of the presentations while simultaneously being overwhelmed by all of the stuff going on in our world. High level points: