Part of the challenge for municipal bond issuers in determining their obligations under Blue Sky laws lies in properly characterizing the nature of the underlying securities. What if, for instance, municipal bonds include real estate, mortgages, leases or other property? Does that suggest the investments are stakes in commercial enterprises rather than municipal bonds?

As we resume our series on state Blue Sky laws, we discuss New York’s special requirements for municipal bonds that consist […]

Under a final rule (the “Final Rule”) recently issued by the Financial Crimes Enforcement Network (“FinCEN”), beginning January 1, 2024, entities that own and operate U.S. real estate must report their “Beneficial Owners”—the natural persons that ultimately own or control such entities—to FinCEN. The Final Rule’s reporting requirements will impact partnerships, joint ventures, REITs, real estate funds, and other active foreign and domestic investors in U.S. real estate. Existing transactional documentation may not adequately address the […]