Public Comment

News & Analysis as of

FTC Recommends Privacy and Data Security Protections for "Internet of Things"

On January 27, 2015, the Federal Trade Commission (FTC) released a staff report, "The Internet of Things: Privacy and Security in a Connected World," setting out the staff's privacy and data security recommendations...more

China’s SAIC Solicits Comments on the Draft Rules on Online Mass Promotion Events

On Jan. 6, 2015, China’s State Administration of Industry and Commerce ("SAIC") issued an announcement to solicit the second round of public comments on the draft of Interim Rules on the Administration on Online Mass...more

Interior Department Proposes to Open Offshore Atlantic Region to Oil and Gas Leasing

The Department of the Interior today announced that it will publish for public comment a draft proposed Five-Year Program (“DPP”) governing the leasing of offshore oil and gas for 2017 through 2022.  Interior’s DPP will...more

MEPA Climate Change Adaptation and Resiliency Policy Available for Public Comment

The Massachusetts Executive Office of Energy and Environmental Affairs (EEA) is accepting public comments on its proposed draft Massachusetts Environmental Policy Act (MEPA) Climate Change Adaptation and Resiliency Policy...more

MIA Announces Opportunity for Comment on Draft Proposed Regulation 31.01.02 on Emergency Powers

On January 23, 2015, the Maryland Insurance Administration issued Bulletin 15-04 to announce a thirty-day opportunity for comment on Draft Proposed Regulation 31.01.02 – Emergency Powers. ...more

CFPB Issues Request For Information on Proposed “Safe Student Account Score Card”

On January 14, the CFPB issued a press release seeking public comments on its “Safe Student Account Scorecard.” The scorecard is a tool for colleges and universities to solicit information on the fees and features of...more

IRS Interim Guidance Creates New Category of Permissible Arrangements - Public Comments Due January 22, 2015

On October 24, 2014, the IRS issued Announcement 2014-67, which “amplifies” Rev. Proc. 97-13 regarding certain management contracts that do not result in private business use. Prior to this Announcement, Rev. Proc. 97-13...more

OEHHA Proposes New Proposition 65 Warning Regulations

On January 12, 2015, California’s Office of Environmental Health Hazard Assessment (OEHHA) published two notices of proposed rulemaking regarding the State’s Proposition 65 warning regulations. OEHHA proposes to repeal...more

Communications Technology Transitions

FCC Seeks Local Government Views - It is rare for the Federal Communications Commission to expressly invite local government participation in formulating communications policy, so when this happens it is worth special...more

FTC Seeks Public Comments on Proposed Merger Study

The Federal Trade Commission (FTC) announced today that it is seeking public comments on a proposed study of the effectiveness of the FTC’s orders in merger cases where it ordered a divestiture or other remedy....more

Special Alert: CSBS Issues Policy, Draft Model Regulatory Framework, and Request for Comment Regarding State Regulation of Virtual...

On December 16, 2014, the Conference of State Bank Supervisors (“CSBS”) issued a Policy on State Regulation of Virtual Currency (the “Policy”), Draft Model Regulatory Framework, and a request for public comment regarding the...more

MEPA Releases Draft Policy on Climate Change Adaptation and Resiliency

The Massachusetts Executive Office of Energy and Environmental Affairs has released for public comment a draft policy on Climate Change Adaptation and Resiliency under the Massachusetts Environmental Policy Act (MEPA)....more

FCC Proposal for Internet Video Programming Could Threaten Cable Franchise Fees

The Federal Communications Commission, in a Notice of Proposed Rulemaking released this month, requested public input about whether it should classify certain Internet-based video programmers as “multichannel video...more

WVDEP Files Proposed Legislative Rule Implementing AST Act

In the latest development relating to West Virginia’s new aboveground storage tank (“AST”) legislation, on December 22, 2014, the West Virginia Department of Environmental Protection (“WVDEP”) filed with the West Virginia...more

Community Banks Adding Prepaid Products Face New Imperatives

It has been well-known in banking compliance law that the Consumer Financial Protection Bureau (“CFPB”) has been planning to issue substantial consumer protection rules with respect to prepaid products. That time has now...more

U.S. Financial Stability Oversight Council Requests Comments on Financial Stability Implications of Asset Management Activities

The Financial Stability Oversight Council (“FSOC”) has taken the next step in its consideration of the asset management industry, by issuing a notice requesting public comment on whether asset management products and...more

SBA Requests Comments on Franchise Loan Program

The U.S. Small Business Administration (SBA) is requesting comments from the public on all aspects of its franchise lending program. The SBA issued its notice and request for comment December 8, 2014....more

FSOC Seeks Comment About Risks Posed by Hedge Funds and Other Asset Managers

The Financial Stability Oversight Council, or FSOC, voted on December 18, 2014 to release a notice seeking public comment regarding potential risks to U.S. financial stability from asset management products and activities,...more

Alert: FCC Seeks Comment on Complex Broadcast Incentive Auction Procedures

In a Public Notice approved in a 3–2 partisan vote, the Federal Communications Commission is asking for comment on the procedures that will govern the Broadcast Incentive Auction, currently scheduled for early 2016. The...more

USPTO Publishes New (and Largely Improved) Guidance for Subject Matter Eligibility

Today the USPTO published its much heralded revised 2014 Interim Guidance on Patent Subject Matter Eligibility under 35 U.S.C. § 101 in view of the Mayo1, Myriad2, and Alice3 Supreme Court decisions. The December 2014...more

Conference of State Bank Supervisors Releases Policy Statement and Draft Model Regulatory Framework for Virtual Currency

Yesterday, December 16, 2014, the Conference of State Bank Supervisors (“CSBS”) released a Policy Statement on state virtual currency regulation, and a Draft Model Regulatory Framework (“Draft Framework”) to support its...more

Blog: OFCCP Opens LGBT Final Rules to Notice and Comment in Response to Pressure from Lawmakers

The Office of Federal Contract Compliance Programs (“OFCCP”) decided to seek public comment on its Final Rule for LGBT workers after being pressured by two Republic Congressmen over its rulemaking process. OFCCP had initially...more

CFPB Proposes Sweeping New Regulations for Prepaid Products

CFPB proposes to regulate a wide variety of prepaid access devices (card-based, electronic, or virtual) as equivalent to credit cards. The Consumer Financial Protection Bureau (CFPB) recently proposed extensive new...more

The Space Between Draft and Final

EPA has a lot to consider in finalizing its rule directing states to create programs to reduce greenhouse gas (GHG) emissions from fossil fuel fired electric generating units. The public comment period on a recently proposed...more

What’s Next for the FDA’s Draft Social Media Guidances?

As many of our life sciences clients know, 2014 brought long-awaited draft guidance documents from the FDA regarding three social media-related topics of interest. The FDA provided its much-anticipated views on...more

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