Covering reported business bankruptcy filings in Massachusetts, Maine, New Hampshire and Rhode Island, and Chapter 11 bankruptcy filings in New York and Delaware listing assets of more than $1 million
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Monday, March 8, 2021
In the fall of 2019, we reported that Vermont enacted Senate Bill 41, which granted the Commissioner of the Vermont Department of Financial Regulation (the “Department”) jurisdiction over entities that administer one or more health reimbursement arrangements (“HRAs”), health savings accounts (“HSAs”), and flexible spending accounts (“FSAs”). Senate Bill 41 directed the Department to adopt rules regulating entities that administer HRAs, HSAs, and FSAs.
In response to Senate Bill 41, the Department recently issued proposed Regulation 1-2021-01 (the “Regulation”) entitled “The Third Party Administrator Rule,” which sets forth licensing and regulatory requirements for TPAs operating in Vermont. Many of the provisions in the Regulation are similar to provisions in the NAIC’s Model Third Party Administrator Act (the “Model Act”).
Friday, March 5, 2021
On 24 February 2021, the UK government published the draft bill for the Administration (Restrictions on Disposal etc. to Connected Persons) Regulations 2021 (the
“Regulations”), which, once in force, will require mandatory creditor approval or an evaluator report before an insolvency practitioner (
“IP”) can dispose of the company’s property by a ‘pre-pack’.
The Regulations are expected to come into effect on 30 April 2021 and we do not expect the detail in the Regulations to change significantly – but do the Regulations address concerns that stakeholders and others have expressed? To a degree, but not as far as some had hoped.
This blog sets out what an IP will need to do before a pre-pack sale can be concluded and the extent to which the Regulations have addressed concerns.
The SEC issued a Risk Alert signaling an exam focus this year on activities of investment advisers, broker–dealers, exchanges, and transfer agents related to Digital Asset Securities, defined as assets distributed and/or transferred using distributed ledger or blockchain technology.