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CalPERS To Consider External Investment Resource Disclosure Rule

Last August the Investment Committee of the California Public Employees’ Retirement System (CalPERS) approved revisions to its External Investment Resource Conflict of Interest Policy. A week later, I asked the Office of...more

2/13/2013 - Administrative Procedure Act CalPERS Conflicts of Interest External Investment Resource Conflict of Interest Policy External Managers Investment Funds Office of Administrative Law Underground Regulation

Could The Product Of Two Debts Really Be A Fortune?

In 628 in the Gurjar capital city of Bhillamala (now, Bhinmal, India), the mathemetician Brahmagupta set out to explain how zero and negatives numbers work. In his book, Brahmasphutasiddhanta, he set forth the rule that the...more

1/30/2013 - Administrative Procedure Act Advertising Dodd-Frank General Solicitation JOBS Act SEC

New Law Lets A Thousand Rules Bloom, But Only Quarterly

Under the Administrative Procedure Act, the Office of Administrative Law is responsible for the review of regulations promulgated by over 200 state agencies. In 2011, reportedly 103 different agencies proposed 467 new rules....more

1/3/2013 - Administrative Procedure Act Secretary of State

DOC Warns Financial Services Licensees And Can A Theory Be A Tautology?

Last April, the Consumer Financial Protection Bureau issued this Bulletin cautioning supervised banks and certain non-depository financial services companies that they must have “an effective process for managing the risks of...more

12/7/2012 - Administrative Procedure Act CFPB Licenses

Court Holds That Same Attorney May Advocate Before The ALJ and Agency Head

The Department of Corporations, like many state and federal agencies, does not observe a strict separation of powers. Indeed, the Department performs quasi-legislative functions in the form of rule making, prosecutorial...more

12/3/2012 - Administrative Procedure Act CalPERS Due Process

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