On February 13, 2026, FinCEN issued an Order providing “exceptive relief” to covered financial institutions (including banks, savings associations, and broker-dealers). The order simplifies the requirements for obtaining beneficial ownership information (“BOI”) for a legal entity customer each time the customer opens a new account. Under the Order, a covered financial institution is required to
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Dickinson-Wright is a Detroit-based firm with over 475 attorneys across more than 40 practice areas and industries. Among a variety of other specialties, the firm represents leading industrial, financial, insurance, emerging technology and service enterprises around the world.
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Understanding Warranty Risk: How Warranties Work – Part 1
Commercial auto, workers’ compensation, and general liability insurance receive the lion’s share of attention from the captive marketplace. This focus is understandable. Commercial auto and workers’ compensation insurance are not only legally mandated but often contractually required. Liability insurance (CGL) indemnifies the insured against the most ubiquitous cause of action – negligence, making it a…
Trump Administration Prohibits SBA Loans to Noncitizens
For years, Small Business Administration (SBA)-backed small business loans were available to borrowers that were at least 51% owned by U.S. citizens, U.S. nationals, and/or U.S. legal permanent residents (LPRs also known as “green card” holders). The Trump Administration has now extended the scope of its efforts to tighten immigration-related policies and rules to qualifications…
Telehealth’s Weight-Loss Boom and the Corporate Practice of Medicine
Telehealth weight-loss platforms offering rapid GLP-1 prescriptions have become one of the fastest-growing segments in healthcare. These platforms connect consumers with clinicians via virtual consultations to assess eligibility for drugs like semaglutide or tirzepatide. This model has attracted significant venture capital as demand surges. Yet, behind the glossy marketing and rapid expansion lies a longstanding…
You Use It, You Pay for It: TRP Brands Reinforces Landlord Rights
When tenant debtors continue to use leased space after filing for bankruptcy, they, by definition, benefit from such use. Landlords often hold off on pressing available remedies because of the debtor’s continued use and failure to reject. The TRP Brands decision confirms that tenant debtors cannot have it both ways: post‑petition use induces landlord reliance, constitutes a…
Texas Hold’em: Governor’s H-1B Pause Reveals Several ‘Hole Cards’
Without any grace period for implementation, investigation results, or opportunity for prior comment by H-1B employers in the State of Texas, Governor Abbott issued a letter on January 27, 2026, addressed to all state agency heads stating that, “The economy of Texas should work for the benefit of Texas workers and Texas employers.” The letter…
The 9th Circuit’s EKRA Ruling: Implications For Behavioral Health and Clinical Labs
Previously published in Healthcare News and Healthcare Michigan
Recently, the Ninth Circuit Court of Appeals affirmed a conviction of a lab operator for violations of the Eliminating Kickbacks in Recovery Act (“EKRA”) in United States v. Schena. This ruling, the first ever appellate interpretation of EKRA, has notable implications for both the laboratory industry and the…
Just Another NDA? Why M&A Confidentiality Agreements Are Different
When it’s time to finally sell your company or if you’re exploring a potential acquisition target, one of the first documents you will encounter is the confidentiality agreement or non-disclosure agreement (“NDA”). You say to yourself, I’ve seen hundreds of NDA’s (perhaps more) in my day-to-day business, so “I’m fine signing just another NDA!” However,…
A Smart Way to Plan for High State Income Taxes: The Nevada ING Trust
As a trust and estates and tax attorney, I am frequently asked by clients (and colleagues) if there are options to reduce the income tax burden they expect to pay on portfolio income or when they expect to experience a liquidity event in the future. Clients who live in high-tax states (e.g., states with a…
Colorado Bankruptcy Court Pushes Back on Chapter 11 Filings by Solvent Debtors
While Chapter 11 does not require debtor insolvency, it does require good faith (applicable to the petition and the plan), which for solvent debtors seeking to reject and modify lease-counterparty rights, includes establishing some level of financial distress susceptible to resolution through the plan process.
Key takeaways
- While Chapter 11 does not require insolvency, it
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