Reporting Requirements

News & Analysis as of

Orrick's Financial Industry Week in Review

SEC Proposes to Amend Rules Governing Its Administrative Proceedings - On September 24, the U.S. Securities and Exchange Commission (the "SEC") proposed to amend rules governing its administrative proceedings. Key...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 12 of 24): Deconstructing Form 1095-C, Parts II...

This series is devoted principally to the reporting requirements imposed by Internal Revenue Code §§ 6055 and 6056 as added by §§ 1502 and 1514 of the Affordable Care Act (ACA), respectively. The former reports offers of...more

Department of Defense Issues New Cybersecurity Rules for Defense Agencies That Use Contractors and Cloud Services to Hold...

The U.S. Department of Defense (DOD) recently published an interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS).1 The interim rule, effective August 26, 2015, focuses on two issues. First, the...more

Bridging the Week - October 2015

ESMA Publishes Final Technical Standards for MiFID II - The European Securities and Markets Authority issued the equivalent of final rules (known as “technical standards”) to implement three cornerstones of the European...more

PRA amends CRD4 reporting rules

PRA has published amendments to the fourth Capital Requirements Directive (CRD4) reporting rules. Following feedback in September to its occasional consultation paper PRA has removed the administrative fee for late reporting....more

CA AG Requires Chief Privacy Officer and Privacy Compliance Program

California’s Attorney General, Kamala Harris, has required Houzz, a home décor information and e-commerce website and mobile app publisher, to hire a chief privacy officer (CPO), conduct a company-wide privacy assessment, and...more

PRA updates skilled persons statement

PRA has updated its supervisory statement that sets out PRA policy and expectations regarding the appointment of, and reporting powers held by, skilled persons. It says the update gives clarity on the use of skilled persons...more

PRA makes Rulebook corrections

PRA has published an administration instrument intending to make changes to the PRA Rulebook. These changes will not affect PRA policy as they provide updates and clarity. The corrections coming into place have the following...more

Have DoD Contractors and Subcontractors Been Drafted? Once Voluntary Defense Industrial Base CS/IA Regulations Now Mandatory and...

When last we left the Department of Defense, they had issued a rather wide-reaching interim DFARS rule addressing cybersecurity practices, data retention, and cloud services purchasing guidance. Now, effective October 2,...more

Pay Attention to the Man Behind the Curtain: DOJ Memorandum Adds Further Weight to CPSC Enforcement Efforts Against Corporate...

The United States Department of Justice (DOJ) recently issued a memorandum to various enforcement agencies. The memorandum, available here, focuses on holding individuals accountable for corporate fraud and misconduct. The...more

FERC Shares Best Practices for Stakeholder Outreach in Gas Project Permitting

The dramatic increase in domestic energy production over the past several years has resulted in the involvement of the Federal Energy Regulatory Commission (FERC) in a wide range of interactions with the public and other...more

Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions - October 2015

This edition of the Cozen O’Connor Aviation Regulatory Update reports on Congress’s six-month extension of FAA’s reauthorization; new U.S. Bilateral Aviation Safety Agreements with the European Union and Canada; the FAA’s...more

What’s the Real Effect of OSHA’s Revamped Inspection Process, the “Enforcement Weighing System?”

On October 1, OSHA started its “Enforcement Weighing System,” which means that OSHA Compliance Officers and Area Offices will be under less pressure to complete a number of inspections and will receive credit for separate...more

SEC Announces Second Wave of MCDC Enforcement Actions

The Securities and Exchange Commission (SEC) this week announced enforcement actions under its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative, targeting 22 municipal bond underwriting firms for alleged due...more

Real Estate and Land Use - September 2015 #2

Use It or Lose It: San Clemente Required to Refund $10 Million in Unused Impact Fees: Walker v. City of San Clemente (August 28, 2015, G050552) - Why It Matters: In a strict reading of a local agency’s...more

A Compilation of Enforcement and Non-Enforcement Actions

Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more

Reporting for ACA Mandates: Final Forms and Additional Guidance

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...more

IRS Releases Final Forms for Health Care Reform Reporting

With required reporting under the Affordable Care Act (ACA) looming, employers should be aware of the latest guidance from the IRS. As a reminder, information reporting requirements apply to all employers who are members of...more

Employee Benefits Developments - September 2015

IRS Issues New Draft Form 1095-C and Instructions. On August 6, 2015, the IRS published its most recent updates to Form 1095-C and the instructions for Forms 1094-C and 1095-C. Beginning in early 2016, applicable large...more

Conflict Minerals Disclosure for Calendar Year 2015: "Conflict Undeterminable" Generally No Longer Permitted

The "DRC Conflict Undeterminable" determination, widely employed in conflict minerals reports to date, will not be permitted for issuers (other than small companies) reporting in 2016 on activities in calendar year 2015. At...more

Back in Court: DMA Argues Before the Tenth Circuit to Follow Quill

Direct Marketing Association (DMA) continued its fight against Colorado’s use tax reporting regime during oral arguments today before the United States Court of Appeals for the Tenth Circuit. After getting sidetracked with a...more

EPA Releases Final Clean Water Act Electronic Reporting Rule

The U.S. Environmental Protection Agency last week finalized its rule to “modernize” Clean Water Act (CWA) regulatory reporting requirements for municipalities, industries, and other facilities....more

PRA invites Solvency 2 reporting questions

PRA has published three Q&A documents regarding Solvency 2. It wants to encourage insurance firms and other organisations working on Solvency 2 to submit questions on reporting to their industry working group on the...more

IRS Proposes Rules for Donee Charitable Donation Reporting

On September 16, 2015, the IRS issued proposed regulations concerning the time and manner for donee organizations to file information returns that report required information about charitable contributions. The proposed...more

Bureau of Economic Analysis (BEA) Issues New Form BE-180 for U.S. Financial Services Providers Including Investment Advisers

Now that the dust has settled a little on the BE-10 benchmark survey responses, U.S. financial service providers, including investment advisers, should take note that the U.S. Bureau of Economic Analysis (the “BEA”) has...more

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