Aggregation Rules

News & Analysis as of

OFAC Issues Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued revised guidance with respect to entities owned 50 percent or more in the aggregate by one or more blocked persons....more

SANCTIONS UPDATE - New Treasury Guidance on Aggregation of Ownership Interests

On August 13, the U.S. Department of the Treasury published revised guidance on the treatment of entities owned by persons whose property and interests in property are blocked under the Executive Orders and regulations...more

OFAC Issues Revised Guidance on Aggregation of Ownership Interests

On August 13, 2014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued revised guidance with respect to the “50% Rule,” which established that an entity owned 50% or more, directly or indirectly, by a...more

CFTC FORM 40/40S Reporting Requirements

Significant amendments to the CFTC’s large trader reporting program will apply as of August 15, 2014. The U.S. Commodity Futures Trading Commission (CFTC) has seemingly increased the number of Form 40/40S requests it...more

DC Circuit Strikes Down EPA “Aggregation” Policy for Regions Outside the Sixth Circuit

On May 30, 2014, the U.S. Court of Appeals for the District of Columbia Circuit nullified an EPA Directive that attempted to reassert its “functional interrelationship” standard for aggregating air pollution sources. This EPA...more

"Developments Regarding Aggregate Contribution Limits"

In the aftermath of the U.S. Supreme Court's decision in McCutcheon v. FEC, striking down the aggregate limits imposed on individual contributions under federal law, several jurisdictions also have taken steps to address...more

CFTC Staff to Host Position Limits and Aggregation Roundtable

Market participants are encouraged to submit further comments to the Commission. The Commodity Futures Trading Commission (CFTC) on May 27, 2014 announced that it will hold a public roundtable at the CFTC on Thursday,...more

The Devil is in the Details: Advising Your Clients on the Affordable Care Act

The Affordable Care Act (ACA) represents a fundamental shift in healthcare delivery and insurance. The law is complex and many of its provisions are delayed due to implementation difficulties. However, virtually all...more

New IRA Rollover Interpretation Has Implications For Banks

In a new interpretation with implications for banks, the Internal Revenue Service (IRS) announced its intent to change course and limit rollovers from an Individual Retirement Account (IRA) to one rollover per year per...more

In wake of McCutcheon case, states abandon aggregate contribution limits

Early this month, the United States Supreme Court invalidated federal aggregate limits on individual political contributions in the case McCutcheon et al. v. Federal Election Commission.... ...In McCutcheon, the Court...more

Supreme Court Opens New Political Contribution Opportunities for Big Donors

In a divided 5-4 ruling in McCutcheon v. Federal Election Commission, the Supreme Court today struck down the federal election law’s long-standing “biennial limit” – the aggregate amount that a person can give to federal...more

U.S. Supreme Court Strikes Down Aggregate Contribution Limits

On Tuesday morning, a divided United States Supreme Court issued its opinion in the case of McCutcheon v. Federal Election Commission (572 U.S. ____ (2014)), striking down a portion of federal campaign finance law that...more

McCutcheon Could Jeopardize NJ Pay-To-Play Restriction; Laurence Laufer and Rebecca Moll Freed Comment for Law 360

The U.S. Supreme Court’s decision in McCutcheon vs FEC striking down aggregate limits on donations to political parties and candidates casts doubt on the constitutionality of similar caps under local pay-to-play ordinances in...more

Supreme Court strikes down individual aggregate contribution limits

The United States Supreme Court has struck down a long-standing campaign finance provision that limited the total amount that individuals may contribute to federal political candidates and committees. The decision, in the...more

United States Supreme Court Invalidates Aggregate Contribution Limits In Federal Campaign Finance Law

Yesterday the United States Supreme Court issued its decision in McCutcheon v. Federal Election Commission, invalidating federal statutory aggregate limits on the amount of money that an individual may contribute to all...more

Supreme Court Campaign Finance Decision Invalidates Aggregate Limits

Yesterday, in a five-to-four decision written by Chief Justice Roberts, the U.S. Supreme Court invalidated the aggregate limits restricting the total contributions individual donors could make to candidates, political action...more

Supreme Court Invalidates Federal Aggregate Limit on Campaign Contributions

The U.S. Supreme Court struck down a key portion of federal campaign contribution laws yesterday morning in McCutcheon v. Fed. Election Commission (No. 12-536). The Court’s 5-4 decision held that federal aggregate limits on...more

"Supreme Court Strikes Down Federal Aggregate Limits on Campaign Contributions"

On April 2, 2014, the U.S. Supreme Court issued its decision in McCutcheon v. FEC, striking down the aggregate limits imposed on individual contributions under federal law. The 5-4 opinion held that the individual aggregate...more

Ramifications of the Supreme Court’s McCutcheon Campaign Finance Ruling

The U.S. Supreme Court’s decision today in an important campaign finance case frees individual political donors to contribute to an unlimited number of federal campaigns and committees, as long as each contribution is within...more

In McCutcheon, the Supreme Court Strikes Down the FEC's Biennial Aggregate Limits

In the most significant campaign finance decision since Citizens United v. FEC, the Supreme Court today struck down the Federal Election Commission's biennial aggregate limits. In McCutcheon v. FEC, the Court left in place...more

Court Issues McCutcheon V. FEC; Strikes Down Aggregate Limits

Today the Supreme Court of the United States issued its decision in McCutcheon v. FEC. The decision, which was 5-4 and authored by Chief Justice Roberts, struck down the aggregate limits under the Federal Election Campaign...more

U.S. Supreme Court Invalidates "Aggregate" Contribution Limits

This morning in McCutcheon v. Federal Election Commission, the U.S. Supreme Court invalidated the “aggregate” contribution limits in federal campaign finance law. Under the ruling, major donors will be permitted to contribute...more

CFTC Proposes New Position Limits for Futures, Options, and Swaps and Amended Aggregation Requirements

Introduction - The U.S. Commodity Futures Trading Commission (“CFTC”) has proposed a comprehensive set of regulations imposing speculative position limits on exchange-traded futures and options contracts and...more

CFTC Re-Proposes Position Limits Rule and Proposes Revised Aggregation Requirements

The US Commodity Futures Trading Commission (CFTC), on November 5, 2013, re- proposed a rulemaking (the Re-­Proposed Rule) that would establish specific limits on speculative positions in 28 physical commodity futures and...more

Recent Trends in Class Action and Aggregate Litigation in the Life Sciences Industry

Introduction - For the last several years, the life sciences industry has been fertile ground for class action and aggregate litigation. Developments in this area have driven several trends, including state consumer...more

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