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Our nationally recognized Appellate & Critical Motions (ACM) Practice delivers sophisticated legal advocacy and analysis before trial, at trial, and on appeal. From state trial courts to the U.S. Supreme Court, our ACM attorneys identify, preserve, and present the critical legal issues that can make the difference between winning and losing.
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For more than a century, Winston has been a trusted advisor and advocate to financial services clients around the world, advising them in some of their highest-stakes and most sensitive matters. Our multidisciplinary Financial Services Industry Group represents leading banks and financial services companies in a range of complex corporate and transactional matters; litigation and disputes; and regulatory, compliance, and enforcement matters.
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Client Alert
|October 29, 2025
|7 Min Read
On October 14, 2025, the Florida Office of Financial Regulation (OFR) published a notice of proposed rulemaking (Notice) to amend certain of its existing anti-debanking rules that implement Florida House Bill 989 (HB 989), which became effective July 1, 2024, and amended Section 655.0323 of the Florida Statutes. If adopted into final form, the proposed amendments would amend Florida Administrative Code Rule 69U-100.323 (Annual Attestation of Compliance) and Rule 69U-100.3231 (Complaint Process Rule).
Client Alert
|May 7, 2024
|6 Min Read
Banks Operating in Florida Should Be Aware of New Florida Rule Before Closing Customer Accounts
On May 2, 2024, Florida Governor DeSantis signed Florida House Bill 989 (HB 989) into law. Among other things, HB 989 amends section 655.0323 of the Florida Statutes, titled “Unsafe and unsound practices,” which the Florida Legislature adopted in 2023 pursuant to Florida House Bill 3 (HB 3).[1] The provisions of HB 989 will become effective on July 1, 2024.
Client Alert
|January 3, 2024
|4 Min Read
On November 20, 2023, Florida Representative Bob Rommel (R-Naples) introduced legislation in the Florida House of Representatives, Florida House Bill 585 (the Bill), requiring certain “financial institutions” (defined below) to file a report with the Florida Office of Financial Regulation (OFR) whenever the financial institution “suspends, terminates, or takes similar action restricting access to a customer’s or member’s account.” If passed, the Bill would become effective on July 1, 2024.
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