News & Analysis as of

Disclosure Requirements Rescission

Williams Mullen

EPA Revises Controversial RMP Regulations

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EPA recently issued a final rule containing much-debated revisions to the Clean Air Act 112(r) Risk Management Program (“RMP”). The rule rescinds or modifies a substantial number of existing requirements, including...more

Hogan Lovells

Gainful employment whiplash: 2014 regulations rescinded

Hogan Lovells on

Although in the past few weeks the U.S. Department of Education (ED) had encouraged institutions to prepare for additional compliance requirements related to gainful employment (GE) that were scheduled to take effect on...more

Ballard Spahr LLP

FTC rescinds FCRA model forms and disclosures

Ballard Spahr LLP on

The Federal Trade Commission (“FTC”) recently rescinded several Model Forms and Disclosures associated with the Fair Credit Reporting Act (“FCRA”), determining they are no longer necessary, given that the CFPB has issued its...more

Proskauer - Labor Relations Update

Concluding the 2016 Persuader Rule Changes “Exceeded Authority” of the LMRDA, DOL Rescinds Them

The Department of Labor fully rescinded the 2016 changes made to the Persuader Rules. The DOL concluded that the 2016 rule changes “exceeded the authority of the Labor-Management Reporting and Disclosure Act (LMRDA)” because...more

Dechert LLP

Financial Services Quarterly Report - Second Quarter 2018: U.S. SEC Issues ETF Rule Proposal

Dechert LLP on

The Securities and Exchange Commission on June 28, 2018 proposed Rule 6c-11 under the Investment Company Act of 1940, together with certain form amendments, which would allow most exchange-traded funds to operate without...more

Bradley Arant Boult Cummings LLP

5 Best Practices For Minimizing Rescission Risk

Recent court decisions across a variety of industries highlight the importance of submitting accurate and complete insurance applications and renewals. When submitting an insurance application, the applicant should accurately...more

Bracewell LLP

SEC Will Not Enforce Part of the Conflict Minerals Disclosure Rule

Bracewell LLP on

On Friday, April 7, 2017, the acting Chief of the Securities and Exchange Commission (the “Commission”) Michael Piwowar released a statement that the Commission will not recommend enforcement of certain parts of its Conflict...more

Akin Gump Strauss Hauer & Feld LLP

President Trump Rescinds the Blacklisting Executive Order

On March 27, 2017, President Trump took the much-anticipated action of rescinding President Obama’s Fair Pay and Safe Workplaces Executive Order 13673 and its underlying regulations (the “Blacklisting Rules,” as it became...more

Foley & Lardner LLP

Final Disability Claims and Appeals Regulations – Be Prepared to Comply

Foley & Lardner LLP on

In December 2016, the Department of Labor issued final regulations under ERISA governing claims procedures for group disability plans, which will become effective January 1, 2018. Generally, these regulations were drafted to...more

Bass, Berry & Sims PLC

Buyer Beware: Lessons of Disclosure Learned the Hard Way

Bass, Berry & Sims PLC on

Government contractors are learning the hard way that agencies need to be kept apprised of major changes within the company during the entire period of bid evaluations. Most recently, the Government Accountability Office...more

Snell & Wilmer

Government Contracting and Executive Orders Under a Trump Administration - Part One

Snell & Wilmer on

With President-elect Trump’s victory, what is the future of President Barack Obama’s executive orders? As President Obama’s administration winds down, the Department of Labor has finalized regulations implementing several...more

Dorsey & Whitney LLP

Who is a Mortgage Broker? Just Ask the Fed.

Dorsey & Whitney LLP on

The United States Court of Appeals for the Second Circuit recently affirmed a magistrate judge’s decision in the District Court for the Eastern District of New York to dismiss a complaint brought under the Truth in Lending...more

Lewitt Hackman

FRANCHISOR 101: Disclosure Violations & Running the Risks of Rescission

Lewitt Hackman on

Despite a district court's recent decision in Braatz, LLC v. Red Mango FC, LLC, franchisors are well advised to comply with applicable disclosure requirements to a "T" to ensure new franchisees will not have an ongoing right...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Jesinoski v. Countrywide Home Loans, Inc.

On January 13, 2015, the U.S. Supreme Court held that borrowers exercising their right to rescind a loan under the Truth in Lending Act must provide written notice to their lender within the three-year rescission period but...more

Foley & Lardner LLP

The Supreme Court Just Held That TILA Rescission Is Accomplished With Notice Alone

Foley & Lardner LLP on

Until today, courts were split over what steps borrowers must take to rescind a home loan. Some courts had ruled that a borrower simply had to send a rescission notice to his creditor within three years after taking out a...more

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