Tag Archives: Disclosure

EBA final guidelines on disclosure requirements of IFRS 9 transitional arrangements

The European Banking Authority (EBA) has published its final guidelines on disclosure requirements of International Financial Reporting Standard 9 (IFRS 9) or analogous expected credit losses (ECLs) transitional arrangements. The guidelines apply to institutions referred to in paragraph 1 of … Continue reading

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OECD Issues Mandatory Disclosure Rules to Combat CRS Avoidance and Offshore Structures

In December, the OECD issued a public consultation document, requiring mandatory disclosure rules to combat CRS avoidance and offshore structures. Comments are due January 15, 2018. The consultation document is prepared in response to the Bari Declaration, issued by the … Continue reading

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CFPB Announces Intent to Reconsider Disclosure Rule

On December 21, 2017, the Consumer Financial Protection Bureau (CFPB) issued a public statement regarding implementation of the Home Mortgage Disclosure Act (HMDA), noting that it plans to reconsider aspects of the mortgage data rule. The HMDA, enacted in 1975, … Continue reading

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“Schumer Box” Disclosure Not “Clear and Conspicuous” As a Matter of Law

Question: Is a Schumer box disclosure describing an APR as "fixed," linked with an asterisk to a paragraph printed just below the Schumer box stating the APR could be increased under three conditions, and also coupled with language, further down … Continue reading

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Ohio Supreme Court Rules Criminal Statute Requiring Disclosure of HIV Status Does Not Violate the First Amendment

In August, the Ohio Supreme Court decided an issue of first impression on the constitutionality of a statute proscribing a person who knows they are HIV positive from engaging in sexual conduct without disclosing that status.  Orlando Batista, represented by … Continue reading

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