Deadlines

News & Analysis as of

Extended SEC MCDC Initiative Deadline Does Little to Lessen Urgency

The Securities and Exchange Commission (SEC) has recently modified its Enforcement Division’s Municipalities Continuing Disclosure Cooperation (MCDC) Initiative in order to encourage as much participation in the program as...more

Don’t forget the September 23, 2014 deadline to ensure your Business Associate Agreements comply with the Omnibus Final Rule

Under the Health Insurance Portability and Accountability Act (HIPAA) Omnibus Final Rule published January 25, 2013, 78 Fed.Reg. 5566, Covered Entities (CEs) with Business Associate Agreements (BAAs) that were entered on or...more

California Finders Bill Trapped In The Weeds As Legislative Deadline Looms

The question of whether finders’ fees can be paid in securities transactions has bedeviled issuers for decades. The Corporations Committee of the Business Law Section of the California has tried to address this recurring...more

Energy Tax Law Alert: IRS Issues New Guidance Regarding Beginning of Construction Requirement for ITC/PTC

On Friday, the IRS issued guidance that clarifies and modifies prior guidance regarding the “beginning of construction” requirement for qualifying for the production tax credit (PTC) under Section 45 of the Internal Revenue...more

EPA Extends 2013 RFS Compliance Deadline, Again

On July 31, 2014, EPA again extended the 2013 Renewable Fuel Standard (RFS) annual compliance reporting and attest engagement reporting deadlines for obligated parties under the law. The Agency issued a direct final rule...more

RFS Update: EPA Indefinitely Extends 2013 RFS Compliance Deadlines, Final 2014 RFS Still Awaited

As reported in a previous blog, EPA in June extended the compliance and attest engagement reporting deadlines for the 2013 Renewable Fuel Standard (RFS) to September 30, 2014 and January 30, 2015 (respectively). Today, EPA...more

Don't Delay: Deadline for ICD-10 Compliance for October 1, 2015 Still Underway

In a final rule released on July 31, the U.S. Department of Health and Human Services (HHS) confirmed October 1, 2015 as the compliance date for health care providers, health plans, and health care clearinghouses to...more

Personnel Deadlines For the 2014-2015 School Year

Reassignment of surplus personnel: When actual student enrollment in a grade level or program, unforeseen before March 1, 2014, permits the assignment of fewer teachers or service personnel to or within a school, the county...more

ICD-10 Compliance Deadline Is Now October 1, 2015

Health care providers, health plans, and health care clearinghouses (“Health Care Entities”) are required to comply with ICD-10 (which stands for the International Classification for Diseases, 10th Edition) on October 1,...more

The MCDC Initiative and Recent Modifications: Window for Issuers and Obligated Persons Now Closes on December 1, 2014, While...

As highlighted in the SEC’s 2012 Municipal Market Report, the SEC has expressed significant concern that many issuers have not been complying with their obligation to file continuing disclosure documents and that federal...more

Most Recent Final Deadline for ICD-10 Implementation is October 1

It’s been a while since CMS set a new “final” deadline for implementation of ICD-10—the greatly expanded medical coding system. So last Thursday CMS issued a new final rule setting October 1, 2015, as the final date for...more

SEC Extends Municipalities Continuing Disclosure Cooperation Initiative Self-Reporting Deadline For Issuers and Obligated Persons...

The Securities and Exchange Commission released a statement on July 31, 2014, modifying certain aspects of its Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”). The MCDC Initiative provides...more

SEC Modifies MCDC Initiative in Response to Industry Concerns

On July 31, 2014, the Securities and Exchange Commission extended the Municipalities Continuing Disclosure Cooperative Initiative (“MCDC”) deadline to allow issuers and obligors more time to complete their reporting...more

SEC Extends the MCDC Initiative Self Reporting Deadline

The Securities and Exchange Commission (“SEC”) just announced modified provisions of the Municipal Continuing Disclosure Cooperation Initiative (“MCDC Initiative”) that extends the self-reporting period for issuers and...more

SEC Modifies MCDC Initiative

On July 31, 2014, the Securities and Exchange Commission (SEC) issued a press release regarding an extension of the deadline for its Municipalities Continuing Disclosure Cooperation initiative (MCDC). The extended deadline...more

SEC Makes Modifications to Municipalities Continuing Disclosure Cooperation (MCDC) Initiative

The Securities and Exchange Commission (SEC) recently announced modifications to its Enforcement Division’s Municipalities Continuing Disclosure Cooperation (MCDC) Initiative. First, the SEC has extended the deadline from...more

SEC Modifies MCDC Terms: Extends Issuer Deadline to 12/01/2014, Lowers Penalty Cap for Small Underwriters; Recognizes Pre-EMMA...

The Securities and Exchange Commission has announced modifications to the terms of its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative. In a press release issued late in the afternoon July 31, 2014, the SEC...more

Property Appeal Deadlines On Horizon

As we noted in our last newsletter, the deadlines for property assessment appeals are looming. Deadlines for these appeals vary by county, but most are either August 1 or September 1, so now is the time to analyze your...more

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

Prudential Regulators Propose Changes To Timing Of Stress Tests

On June 12, the Federal Reserve Board and the OCC separately released proposed rules that would push back by 90 days the start date of the stress test cycles and the deadlines for submitting stress test results....more

Underwriters, Universities and Government Debt Issuers Face a Critical Deadline [Video]

Join Pepper Hamilton in a special webinar examining the latest developments in the U.S. Securities and Exchange Commission’s Municipalities Continuing Disclosure Cooperation Initiative (MCDC Initiative), including what...more

Complying With The Rules Is Important In The Business Court

There's an ominous sounding sentence in a Business Court decision this week: A party practicing before the North Carolina Business Court should take the deadlines imposed by its orders and the rules of practice very...more

As Sunshine Act Reporting Deadline Looms, CMS Issues Additional Guidance

With the June 30 deadline for Phase 2 Sunshine Act reports by pharmaceutical and medical device manufacturers (“Applicable Manufacturers”) and group purchasing organizations (“GPOs’) quickly approaching, the Centers for...more

Applicable Manufacturers Face June 30th Deadline for Sunshine Act Reporting

CMS will begin to enforce what could be significant penalties on manufacturers who fail to report required data. The Centers for Medicare & Medicaid Services (CMS) has announced a short timeframe before detailed...more

Winding the Removal Clock: The Second Circuit Clarifies The Deadline for Removal Under the Class Action Fairness Act

When faced with a state court lawsuit, a critical consideration for any defendant is the forum in which to litigate – whether to remain in state court or, if possible, remove the case to federal court. In the case of a...more

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