Reminders Versus Demands
June’s Housing Security and Tenant Protection Act imposed a new requirement on landlords in the event their...
The OCC, Banks and the Federal Courts
I don't normally blog about court decisions, but in 2015, the United States Court of Appeals, in a case ref...
Give Your Account Documents a Checkup
In 2008, I wrote in the Business Law Journal that legal developments lagged behind technology so banks need...
Court Holds 6-Month Limitation Period “Unreasonable and Unenforceable”
It has long been established that parties to a contract may agree to shorten the statute of limitations.
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Down Goes Frazier (FinTech)
The knockout punch was in May when a federal judge decided that offering a national FinTech charter exceede...
It’s Not Quite Schadenfreude, But Now Maybe Other Businesses Will Understand Your Pain
In the closing rush of the legislative session in July, New York adopted a statute that requires all busine...
Don’t Abandon the Abandoned Property Law. You May Lose Interest.
Busybodies, like whistleblowers, can sue to collect money fraudulently withheld from New York State, and sh...
The GAO Criticizes FinCEN For Not Communicating CTR and SAR Metrics. But Is Communication Enough?
In August, the GAO issued a report titled, “Agencies and Financial Institutions Share Information but Metri...