Final Rules Reporting Requirements

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The New “Persuader Rule” and Its Impact on Manufacturers

The federal Office of Labor-Management Standards (“OLMS”) in the Department of Labor issued a Final Rule, on March 24, 2016, that significantly reinterprets the so-called Persuader Activities Rule. This rule represents the...more

The ERISA Litigation Newsletter - April 2016

Editor's Overview - This month we feature three key developments. First, we review the U.S. Supreme Court's decision in Gobeille v. Liberty Mut. Ins. Co., 136 S. Ct. 936, 947 (2016) wherein the Supreme Court held that a...more

No-Action Letter Issued Regarding the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the ownership and control final rule (the “OCR Final Rule”). The OCR Final Rule requires...more

Department of Labor’s Long-Debated “Persuader” Regulations Expand the Scope of the Consulting Relationships that Must be Reported...

The U.S. Department of Labor’s Office of Labor-Management Standards (“OLMS”) recently issued its long-debated “persuader” regulations which, as of July 1, 2016, will require employers and their labor relations consultants,...more

Next Steps: Helping Your Organization Implement the New Medicare Overpayment Rule - Part II

On February 12, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule that explains the requirements for providers and suppliers reporting and returning overpayments under Medicare Parts A & B (the...more

Next Steps: Helping Your Organization Implement the New Medicare Overpayment Rule - Part I

On February 12, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule that explains the requirements for providers and suppliers reporting and returning overpayments under Medicare Parts A & B (the...more

Employment Law Developments for Manufacturers:  Predictably Unpredictable!

Manufacturers should take note of two recent developments in the human resources world. One expected. The other not. Frequent readers of this blog may recall that in January I predicted the United States Department of...more

DOL Suspends Filing of Certain Parts of Required Form LM-21 Reports

On April 13, 2016, the Office of Labor-Management Standards (OLMS) at the U.S. Department of Labor (DOL) issued a Form LM-21 Special Enforcement Policy announcement. Effective immediately, the policy is suspending the...more

More Updates on the Legal Challenge to DOL’s Final Persuader Rule

The plaintiffs in the first lawsuit challenging the Final Persuader Rule have filed a motion for preliminary injunction, and the U.S. Chamber of Commerce seeks to file an amicus brief in support of that motion. In...more

New DOL “Persuader” Rule Stimulates Exaggerated Persuader Activities by Proponents and Opposition

We will try to keep this straightforward and polemic free. We will try. The last time there were any significant changes to the National Labor Relations Act was in 1959, when Congress passed the Landrum-Griffin bill...more

CMS Clarifies 60-Day Reporting Requirements For Medicare Parts A & B

The Centers for Medicare and Medicaid Services (“CMS”) has clarified the reporting requirements and lookback period for overpayments from Medicare Parts A and B in Final Rule 6037 (“Final Rule”), issued by CMS on February 12,...more

EPA Publishes Final Rule on Partial Exemption of Certain Chemical Substances from Reporting Additional Chemical Data In The...

On March 29, 2016, the U.S. Environmental Protection Agency (EPA) published the Partial Exemption of Certain Chemical Substances from Reporting Additional Chemical Data final rule in the Federal Register. This final rule...more

DOL Releases Final "Persuader" Rule, Touting Transparency

In a move highly anticipated and supported by unions, the U.S. Department of Labor (DOL) issued its final “persuader” rule on March 23, 2016. The revised rule expands the information which must be disclosed by employers and...more

DOL Issues Final "Persuader" Rules Governing Disclosure of Consultants in Antiunion Efforts

On March 23, 2016, the federal Department of Labor issued final regulations requiring for the first time that employers disclose the identity of any third-party consultants retained to help the company respond to union...more

Employers Must Prepare Immediately for the Persuader Rule

On March 23, 2016 the United States Department of Labor issued its final “persuader rule” for publication. The persuader rule “modifies” the “advice exemption” under the Labor-Management Reporting Disclosure Act of 1959...more

The Final Persuader Rule: What You Need to Know About the New Reporting Requirements

On March 23, 2016, the U.S. Department of Labor (DOL) issued final regulations revising the “advice exemption” and requiring employers and consultants (including lawyers) to report labor relations advice and services under...more

Employers Face New Reporting Requirements after DOL Issues Final Persuader Rule

On March 23, 2016, the Department of Labor (“DOL”) finalized its long anticipated “persuader” rule, which requires that employers and legal consultants report pay arrangements regarding any attempts to persuade employees,...more

DOL Publishes Final Rule Requiring Employers to Disclose Persuader Agreements

For many years, employers have been able to lawfully avoid certain reporting requirements under the Labor Management and Reporting Disclosure Act which compels the disclosure of agreements with outside...more

U.S. Department of Labor Publishes New Persuader Rule

The U.S. Department of Labor (DOL) published on March 23, 2016, its controversial "persuader" rule concerning labor relations activity that will force many employers and their law firms to file reports annually with the...more

Department of Labor Publishes Long-Awaited “Persuader” Final Rule

On March 24, the Department of Labor published its long-awaited revisions to its regulations regarding the “persuader” reporting requirement under Section 203 of the Labor Management Reporting and Disclosure Act (LMRDA). As...more

Lifting the Curtain on Union Organizing Campaigns

Office of Labor-Management Standards (OLMS) Final Rule on Persuader Reporting Increases Transparency for Workers - The Persuader Final Rule realigns the Department’s regulations with the text of a law passed by Congress,...more

DOL Issues Final Union “Persuader” Rule

On March 24, 2016, the Department of Labor (DOL) published the long-awaited final union “Persuader Rule,” which significantly expands the public reporting requirements of employers and their consultants (including attorneys)...more

Department of Labor Issues Long-Awaited "Persuader Activity" Final Rule

On March 24, 2016, the U.S. Department of Labor (DOL) issued a final rule, 81 Fed. Reg. 15924, that will require employers to file public reports with the DOL when they use consultants (including lawyers) to provide labor...more

CFTC Approves Final Rule to Amend the Trade Option Exemption by Eliminating Certain Reporting and Recordkeeping Requirements for...

On March 16, the U.S. Commodity Futures Trading Commission approved a final rule that eliminated certain requirements “for trade option counterparties that are neither swap dealers nor major swap participants[.]”...more

CFTC Adopts Final Trade Option Rule

On March 16, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved amendments to the rules applicable to certain physically-settled options referred to as “trade options.” This final rule substantially...more

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