Tagged: no action letter

When Does A “Digital Asset” Qualify As A Security? A Deeper Dive Into Recent SEC Guidance.

Here’s a question for all of you. Between coins, tokens, stamps, tickets, vouchers, and chips, which of these qualifies as a “security” under U.S. Securities laws? It’s actually a trick question, they all do! Well, technically speaking, they all could potentially qualify as securities. The… Read More

Is the No Action Letter for TurnKey Jet a No-Action Non Event? Doug Ellenoff Comments on SEC Digital Asset Statement and STO Framework

Last week, the Securities and Exchange Commission (SEC) moved forward on clarifying their position regarding digital assets. First, a No-Action Letter (NAL) was released pertaining to the issuance of a token by TurnKey Jet. In a tightly defined issuance, Turnkey was deemed not to be… Read More

Here is the No Action Letter by the CFPB Regarding Upstart’s Request

The Consumer Financial Protection Bureau (CFPB) has issued its first no action letter to online letter Upstart. At the time of the request by Upstart, the online lender had facilitated over 80,000 loans totaling over $1 billion ranging from $1,000 to $50,000 with a term of… Read More

Did Lending Just Change for Good?

Bank lending regulations have rarely been thought of as dynamic or exciting but last night’s ruling by the Consumer Financial Protection Bureau (CFPB) to allow a lender to begin using alternative data in their underwriting could herald the beginning of a new era in lending… Read More

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