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Bass, Berry & Sims PLC

The Time is Here: Public Companies Should be Mindful of the Upcoming Insider Trading Policy Form 10-K Exhibit Filing Requirement

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In connection with the upcoming Form 10-K/proxy season, public companies with a fiscal year ending on December 31 will be required, for the first time, to publicly file their insider trading policies as exhibits to their...more

Foley & Lardner LLP

California’s Legislature Pushes Forward with Climate Accountability Bills

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After not accepting California Governor Newsom’s proposal to delay implementing California’s Climate Accountability laws by two years, the California legislature passed amendments on August 31, 2024, to California’s 2023...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Schedule 13G Accelerated Filing Deadlines Effective September 30, 2024

As we noted in prior client alerts (available here and here), in 2023 the Securities and Exchange Commission (SEC) adopted amendments to its beneficial ownership rules. The amended rules include accelerated filing deadlines...more

Ballard Spahr LLP

Year-End CTA Filing Deadline Is Quickly Approaching

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The federal Corporate Transparency Act (CTA) became effective on January 1, 2024, and despite multiple challenges and ongoing court cases, the CTA remains in effect. The CTA requires many entities to file beneficial ownership...more

Foley Hoag LLP

TIC Form SHL-Reporting of Foreign Holdings of U.S. Securities Due August 30, 2024

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Form SHL is a five-year mandatory benchmark survey filing commissioned by the Department of the Treasury and administered by the Federal Reserve Bank of New York (“FRBNY”) applicable to all U.S.-resident issuers with foreign...more

Perkins Coie

Corporate Transparency Act Midyear Update: Game-Changing FinCEN Guidance and What To Do To Meet Year-End Filing Obligations

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June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more

Neal, Gerber & Eisenberg LLP

Corporate Transparency Act - Overview of Filing Requirements

Background - The Corporate Transparency Act of 2019 (“CTA”) became effective on January 1, 2024. Under the CTA, all “reporting companies” must file a Beneficial Ownership Information (BOI) report with the Financial Crimes...more

Torres Trade Law, PLLC

The Corporate Transparency Act: Treasury’s New Back Door for Finding CFIUS Non-Notified Transactions

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Much has been written about the Corporate Transparency Act (“CTA”), which was enacted on January 1, 2021, and went into effect on January 1, 2024. Briefly, the CTA requires “reporting companies” to disclose beneficial...more

Seyfarth Shaw LLP

Update: Governor Healey Signs Massachusetts Pay Transparency Bill into Law - July 31, 2024

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After an extended legislative process, pay transparency requirements are coming for Massachusetts employers. On July 24, 2024, the Massachusetts House and Senate passed a bill requiring employers with over 25 or more...more

Seward & Kissel LLP

August 30 Deadline for TIC Form SHL

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Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

Eversheds Sutherland (US) LLP

Swiss sign Model 1 IGA with United States and resolve transition issues

On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more

King & Spalding

Corporate Transparency Act: Entities That No Longer Exist May Need to File BOI Reports According to New FinCEN FAQs

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Since January 1, 2024, when the Corporate Transparency Act’s (“CTA”) beneficial ownership reporting requirements became effective, a key issue has been whether companies that meet the requirements of a “reporting company” are...more

Latham & Watkins LLP

FDIC Expands Resolution Plan Requirements for Banks with Assets of $50B or More

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Insured depository institutions with $50 billion to less than $100 billion in average total assets are subject to new resolution reporting standards, with enhanced reporting for those with average total assets of $100 billion...more

Verrill

Mid-year assessment: Are you in good shape on CTA compliance?

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The Corporate Transparency Act (CTA) will require most privately-owned entities to file Beneficial Ownership Information (BOI) reports with FinCEN no later than January 1, 2025. The purpose of this Client Alert is to check in...more

Ankura

10 Tips for More Effective Change Reporting

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Congratulations! Your money service business (MSB) has gone through the grueling process of building out all business functions, writing and implementing policies and procedures, and acquiring licenses for your covered...more

Sullivan & Worcester

Deadline for Form 13F Filers for New Reporting Requirements on Executive Compensation Votes Rapidly Approaching

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The Securities and Exchange Commission adopted rule and form amendments that will require institutional investment managers who file Form 13F to use Form N-PX to report how they voted proxies on executive compensation (or...more

Jenner & Block

Reporting Requirements under the Corporate Transparency Act

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The Financial Crimes Enforcement Network of the Department of the Treasury (FinCEN) issued final regulations under the Corporate Transparency Act (CTA) which, effective January 1, 2024, require most companies (i.e.,...more

Ruder Ware

New Filing Requirements – Corporate Transparency Act

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The Corporate Transparency Act (CTA) is a recent enactment that mandates increased transparency in entity ownership structures, aiming to combat illicit activities such as money laundering and terrorism financing facilitated...more

Ballard Spahr LLP

FinCEN Releases Updated BOI FAQs

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On April 18, the Financial Crimes Enforcement Network (“FinCEN”) released updated FAQs related to the Corporate Transparency Act (“CTA”) and Beneficial Ownership Information (“BOI”) Rule. The last round of updates occurred in...more

Cooley LLP

New SEC Requirements for Form 13F Filers Effective July 1, 2024

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In late 2022, the Securities and Exchange Commission (SEC) adopted rule changes that will require institutional investment managers who file Form 13F to annually file a Form N-PX disclosing the manner in which they have voted...more

Woods Rogers

Corporate Transparency Act: What You Need To Know

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The Corporate Transparency Act (CTA) went into effect on January 1, 2024, creating a national beneficial owner database to be used in combating money laundering,  by requiring companies to report information about their...more

Verrill

RxDC Reporting in Light of June 1, 2024 Deadline and Recent PBM Litigation

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Under the Consolidated Appropriations Act of 2021 (“CAA”), employer-sponsored group health plans, including medical-only plans, must submit information about their prescription drugs and health care spending. This submission...more

Snell & Wilmer

Donning the Plan, Forgetting the Top Hat: A Common Oversight in ERISA Compliance

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When drafting a deferred compensation plan or agreement for a key employee (a “top hat plan”), the focus is almost always on the terms of the plan. In the process, many employers miss a crucial step—filing the top hat...more

Perkins Coie

Get Ready for the New York LLC Transparency Act

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On March 1, 2024, New York Governor Kathy Hochul signed an amended version of the New York LLC Transparency Act (NYLTA), which was originally signed with provisions for amendments in December 2023. The NYLTA will go into...more

Fox Rothschild LLP

IRS Issues New Guidance for Cannabis Companies That Receive Over $10K in Cash

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The IRS’s Office of Chief Counsel recently published a memorandum providing information for cannabis companies struggling to comply with the completion of Form 8300, which must be filed every time a company receives a cash...more

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