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Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – February 2026 # 4

To keep you informed of recent activities, below are several of the most significant federal events that have influenced the Consumer Financial Services industry over the past week....By: Troutman Pepper Locke

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HMT Policy Response On Applying FSMA 2000 Model Of Regulation To UK CRR

HM Treasury (HMT) has published a policy update response on applying the Financial Services and Markets Act 2000 model of regulation to the UK Capital Requirements Regulation (UK CRR), following its July 2025 consultation on Basel 3.1, the overseas recognition regimes and key UK CRR definitions. In this response, HMT broadly maintains its proposed approach while making targeted clarifications in response to feedback....By: A&O Shearman

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SEC Division of Corporation Finance Updates Compliance & Disclosure Interpretations

On January 23, 2026 and on February 11, 2026, the SEC’s Division of Corporation Finance updated its Compliance and Disclosure Interpretations (“C&DIs”) by adding new questions and responses, revising some responses and withdrawing others. These updates are consistent with Chairman Paul Atkins’ focus on modernizing existing rules, reducing disclosure burdens, and prioritizing efficiency and lower costs for market participants....By: Jackson Walker

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Project Finance in the Data Center Sector: Structuring for Scale and Certainty

Sustained demand, scalability, and investor-friendly project financing structures are helping to rapidly position data centers as critical infrastructure in the modern economy. Project finance in particular is playing an increasingly central role in how these assets are developed, capitalized, and brought to market....By: Morgan Lewis

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Top 5 SEC Enforcement Developments for January 2026

Additionally, there were several notable leadership changes at the SEC in January. On January 2, Commissioner Caroline Crenshaw’s term concluded, leaving the agency with just three commissioners and no Democratic appointees. The SEC’s Divisions of Enforcement and Examinations also filled key leadership positions in January....By: Morrison & Foerster LLP

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FINRA Triples Long-Standing Annual Gift Limit

The U.S. Securities and Exchange Commission (SEC) on February 12, 2026, approved the Financial Industry Regulatory Authority's (FINRA) amendment to Rule 3220 (Influencing of Rewarding Employees or Others), commonly referred to as the "Gifts Rule."...By: Holland & Knight LLP

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UK FCA Confirms Forbearance In Relation To Issuer Notifications In Respect Of A Block Listing

The UK Financial Conduct Authority (FCA) has published a statement clarifying how issuers should comply with notification requirements for new shares admitted to trading following the commencement of the Public Offers and Admissions to Trading Regulations 2024 (POATRs) on 19 January....By: A&O Shearman

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Why Hiding Information From Your Plan Provider Always Backfires

I understand why some plan sponsors withhold information from their plan providers. Sometimes it’s embarrassment. Sometimes it’s fear of added cost. Sometimes it’s just not knowing what matters. Unfortunately, in the retirement plan world, hiding information never protects you—it only delays the damage....By: Ary Rosenbaum - The Rosenbaum Law Firm P.C.

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Healthcare & Life Sciences Private Equity Deal Tracker: Kinderhook to Acquire Enhabit

Kinderhook Industries will acquire Enhabit in a deal value at approximately $1.1 billion, according to a news release. Enhabit (NYSE: EHAB), founded in 2022 when it was spun off from Encompass Health Corp. and based in Dallas, is a national home health and hospice provider....By: McGuireWoods LLP

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Financial Services AI Risk Management Framework: Operationalizing the 230 Control Objectives Before the Market Wakes Up

At the end of 2025, we wrote that the defining question for 2026 would no longer be whether artificial intelligence (AI) is being used responsibly but whether organizations truly understand and govern the systems they have already built, now that AI has removed their margin for error....By: Lowenstein Sandler LLP

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[Video] Great Women in Compliance: Proof, Patterns & Power: The Real Art of Workplace Investigations

In this roundtable episode, Sarah Hadden and Ellen M. Hunt explore the real art of workplace investigations with guests Lloydette Bai-Marrow and Onyinye Asala-Olojola through these three lenses: • Proof: What evidence do you need to support your finding that not only holds up in a court of law but also withstands scrutiny • Patterns: How to connect the dots so that the investigation tells a meaningful story that leads to action • Power: How to manage leaders so that the best resolution for the...By: Thomas Fox - Compliance Evangelist

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[Audio] TMA Chicago/Midwest Podcast Hosted by Paul Musser: Chapter President Sandy Prabhakar on Referral Networks, Market Uncertainty and “Pipeline to Prosperity”

In the first episode of the new year, the TMA Chicago/Midwest Podcast welcomed Sandy Prabhakar, the chapter's 2026 president and Managing Director at Armory Group. Sandy, who has over 20 years of experience advising clients on mergers and acquisitions, refinancings and restructurings, returned as the podcast’s first two-time guest to discuss his path to leadership within TMA and the chapter’s theme for the year, “Pipeline to Prosperity,” which will focus on boosting engagement from members and...By: Katten Muchin Rosenman LLP

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CFTC Files Amicus Brief Urging Exclusive Federal Jurisdiction of Event Contracts

On February 17, 2026, the Commodity Futures Trading Commission (CFTC) filed an amicus curiae brief in the Ninth Circuit supporting North American Derivatives Exchange, Inc., d/b/a Crypto.com Derivatives North America (Nadex/Crypto.com) in its appeal of the District of Nevada’s order denying its request to enjoin Nevada gaming regulators from taking action against its sports-based event contracts....By: WilmerHale

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[Audio] California DFPI's Next Target: Credit Reporting Industry — Regulatory Oversight Podcast

In this special crossover episode of Regulatory Oversight and FCRA Focus, Kim Phan is joined by Michael Yaghi, partner in Troutman Pepper Locke's Regulatory Investigations, Strategy, and Enforcement practice group, to unpack the California Department of Financial Protection and Innovation's (DFPI) latest effort to require registration for the credit reporting industry. They discuss DFPI's second request for comment, how it fits into California's broader push to regulate nonbank financial...By: Troutman Pepper Locke

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New York Rolls Out Nation's First Comprehensive Buy Now, Pay Later Regulations

New York has officially fired the starting gun on what is poised to become the most comprehensive regulatory framework for buy now, pay later lending in the United States. On Feb. 23, 2026, Gov. Kathy Hochul announced that the New York Department of Financial Services had published proposed rules implementing the state's BNPL law, which the governor signed on May 9, 2025, as part of her FY26 Budget....By: Fox Rothschild LLP

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[Video] AI Today in 5: February 25, 2026, The Spotting AI Fakes Edition

Welcome to AI Today in 5, the newest addition to the Compliance Podcast Network. Each day, Tom Fox will bring you 5 stories about AI to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the AI Today In 5. All, from the Compliance Podcast Network. Each day, we consider five stories from the business world, compliance, ethics, risk management, leadership, or general interest about AI. Top AI stories include: • No code AML. (FinTechGlobal):...By: Thomas Fox - Compliance Evangelist

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[Audio] Trading, Gambling, or Something Else? Prediction Markets and the Payments Puzzle — Payments Pros – The Payments Law Podcast

In this crossover episode, Payments Pros host Keith Barnett teams up with Regulatory Oversight host Stephen Piepgrass to unpack how prediction markets, gaming, and payments intersect in a rapidly evolving and legally uncertain landscape. Drawing on Keith's extensive regulatory experience, they explain what prediction markets are, why these contracts are treated as swaps rather than securities, and how that distinction affects insider trading issues. Keith and Stephen then address the growing...By: Troutman Pepper Locke

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[Video] Compliance into the Weeds: FCPA Trial Rarity: Charles Hobson Convicted

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore it more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly look at the recent conviction of Charles ‘Hunter” Hobson for FCPA violations. Former Corsa Coal senior sales executive Charles Hunter Hobson was...By: Thomas Fox - Compliance Evangelist

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SEC Proposes Amendments to Form N-PORT and Extends Names Rule Reporting Compliance Dates

Who may be interested: Registered Investment Companies; Boards of Directors; Investment Advisers; Compliance Officers; Fund Administrators Quick Take: The SEC proposed amendments to Form N‑PORT that would extend filing deadlines, reduce the frequency of public reporting, streamline reporting requirements, and eliminate “Names Rule” reporting from the form. Separately, the SEC extended the compliance dates for Names Rule‑related Form N‑PORT reporting, giving fund complexes additional time...By: Seward & Kissel LLP

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[Video] Podcast – Proyecto de circular: Los cambios en compliance

La Superintendencia de Sociedades de Colombia publicó recientemente el proyecto de modificación de la Circular Básica Jurídica, mediante el cual se unifican el Sistema de Autocontrol y Gestión del Riesgo Integral LA/FT/FPADM (SAGRILAFT) y el Programa de Transparencia y Ética Empresarial (PTEE). Este proyecto busca identificar, gestionar y medir, a través de un solo programa, los riesgos de lavado de activos, financiación del terrorismo, proliferación de armas de destrucción masiva, corrupción...By: Holland & Knight LLP

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