It was a busy July for briefing before (i) the U.S. Court of Appeals for the 10th Circuit for its en banc review in National Association of Industrial Bankers v. Weiser,1 and (ii) the U.S District Court in Oregon in National Association of Industrial Bankers v. O’Day.2 See our ALERTS of Apr. 2, 2026 and June 16, 2026.
Month: August 2026
Ten States Sue Occ Over Escrow Preemption Rule
Ten states, led by Oregon and New York, have sued the Office of the Comptroller of the Currency (“OCC”) to block the OCC’s recent preemption rule regarding state interest-on-escrow requirements. Complaint, Oregon v. OCC, No. 3:26-cv-1672 (D. Or. filed Aug. 11, 2026); see our ALERT of Jan. 2, 2026; see also our ALERT of May 11, 2026.
Fincen Permanently Ends U.S. Beneficial Ownership Reporting
On August 11, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a final rule that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership (UBO) information to FinCEN under the Corporate Transparency Act. FinCEN will also delete previously reported information on U.S. persons.