Disclosure Requirements

News & Analysis as of

New Guidance on Contractor Self-Disclosure

The Health and Human Services (HHS) Office of Inspector General (OIG) provides health care providers an opportunity to disclose potential violations of certain Federal civil and criminal laws in relation to HHS contracts or...more

And Now More Disclosure Requirements for Federal Contractors – Employee Compensation

Federal contractors and subcontractors that have 100 or more employees and a federal contract, subcontract or purchase order exceeding $50,000 should pay close attention to a new rule proposed by the Department of Labor’s...more

President Obama Issues New Executive Order on Fair Pay and Safe Workplaces

On July 31, President Obama issued an Executive Order requiring federal contractors to disclose past labor violations. The order applies to new contracts for goods and services, including construction, valued at more than...more

Revised Draft Rule G-42: MSRB Continues to Fine-Tune Rules Applicable to Municipal Advisors

On July 23, 2014, the Municipal Securities Rulemaking Board (MSRB) issued Regulatory Notice 2014-12 requesting comments on a revised draft of MSRB Rule G-42 on standards of conduct and duties of municipal advisors when...more

Recent Developments for Federal Contractors

Companies and individuals seeking to do business with the federal government have been targeted in the “year of action” promised by President Barack Obama. The President has taken steps to impose a number of additional labor...more

The Double Whammy: Cubist’s Recent FCPA Disclosure

In the FCPA enforcement world, corporate disclosures of potential violations carrying significant messages. Cubist Pharmaceuticals (Cubist) disclosed in a Form 10-Q that its subsidiary, which it acquired last year...more

No RESPA Respite - Continued

The CFPB continues to crack down on basic RESPA violations. On August 12, 2014, the CFPB announced yet another Consent Order with alleged violations of RESPA. In this case, an on-line retail mortgage company, the company’s...more

In Wyoming, a Higher Burden for Chemical Disclosure Exemption?

In Powder River Basin Resource Council v. Wyoming Oil and Gas Conservation Commission, the Wyoming Supreme Court held that the Wyoming Oil and Gas Conservation Commission has the burden of justifying the use of trade secrets...more

Amnesty International Continues to Push for En Banc Rehearing in Conflict Minerals Case

Amnesty International has filed a supplemental brief which continues to advocate for a rehearing en banc in the conflict minerals case. The argument is this: American Meat Institute v. U.S. Department of Agriculture...more

Disclosure At The Mobile Check-Out: The FTC's View On Mobile Shopping Apps

In its August 1st report entitled "What's the Deal — An FTC Study on Mobile Shopping Apps," the FTC provides guidance on various disclosures that should be made by mobile apps along with reinforcing a number of prior...more

The JOBS Act and IPO Volume

An academic study titled “The JOBS Act and IPO volume: Evidence that disclosure costs affect the IPO decision” (Dambra, Field, and Gustafson, available through SSRN) provides an interesting analysis of the effect of the JOBS...more

Potential Blacklisting of Government Contractors Based on Labor Law Violations

On July 31, 2014, President Obama signed Executive Order 13673, which will require companies bidding on federal contracts to disclose to agency contracting officers any violations (whether by administrative merits...more

FinCEN Seeks to Turn Beneficial Ownership Disclosure of Private Entities on its Head

My colleagues over at our banking blog have highlighted proposed regulations by the Financial Crimes Enforcement Network, or FinCEN, under the Bank Secrecy Act which are meant to combat illicit financial activity, including...more

FTC Reports Mobile Shopping App Consumer Disclosures Are Insufficient

On August 1, the FTC released a staff report on the agency’s review of shopping apps—those used for comparison shopping, to collect and redeem deals and discounts, and to complete in-store purchases. ...more

Sunshine Ordinance Preempted by City Charter Provision Creating Attorney-Client Privilege

The First District Court of Appeal determined that City of San Francisco (“City”) resident Allen Grossman (“Grossman”) was not entitled to documents related to the development of certain San Francisco Ethics Commission...more

SEC Brings Another Bond Case Against A State

The SEC’s nationwide review of municipal bond disclosures yielded another enforcement action, this time against the state of Kanas. The Order centers on claims that the state failed to disclose its huge unfunded pension...more

President Obama Signs Executive Order Requiring Federal Contractors to Disclose Labor Violations

Last week, the White House continued its efforts to advance its labor agenda through measures not requiring congressional approval. The president signed an executive order that will require certain federal contractors to...more

EBA Publish Final Draft RTS on Equity Exposures

On August 5, EBA published its final draft regulatory technical standards (RTS) specifying the treatment of equity exposures according to Article 495(3) of Regulation No 575/2013 Capital Requirements Regulation (CRR). ...more

OFCCP Will Require Contractors to File Equal Pay Report

Implementing the President's April 2014 Memorandum directing the Department of Labor to develop a data collection tool to advance the goal of pay equity, the Office of Federal Contract Compliance Programs (OFCCP) has...more

Executive Order Continues Focus on Labor Laws for Contractors

Under an Executive Order signed by President Obama on July 31, 2014, contractors and subcontractors are faced with a wave of new obligations concerning labor laws and pre-dispute arbitration agreements. The provisions of the...more

Federal Contractors May Lose Contracts Because of Labor and Employment Law Violations

And here we go again. We have noted that the National Labor Relations Board is aggressively expanding employee protections and organized labor opportunities, that the EEOC has decided to claim many common provisions of...more

Reg A+ Challenged Again

Another letter to the SEC from the Hill challenges the Regulation A+ proposal. This time, the authors question the authority of the SEC in defining “qualified purchaser” as an offeree or purchaser in a Tier 2 Reg A+...more

Another Hoop For Government Contractors: The Fair Pay and Safe Workplaces Executive Order

On Thursday, July 31, 2014, President Obama signed another in a series of recent Executive Orders targeting employment practices of federal government contractors and subcontractors. Under the “Fair Pay and Safe Workplaces”...more

Federal Contractors Beware – Part 4

On August 6, 2014, the Office of Federal Contract Compliance Programs (OFCCP) released a proposed rule requiring federal contractors to provide “summary” compensation data, as instructed by President Obama in his April 8,...more

Weekly Update Newsletter - August 2014 #2

In this issue: - Obama Signs Order Boosting Federal Contract Worker Rights - DoD Issues Interim Rule to Amend DFARS Foreign Commercial Satellite Services (DFARS Case 2014-D010) - Obama Administration...more

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