Public Comment

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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

State AGs Looking to Crack Down on Telemarketers Press FCC and FTC

A majority of the nation’s state and territorial Attorneys General have collectively urged the Federal Communications Commission and Federal Trade Commission to revisit rules and policies in ways that would help law...more

NMFS Proposes Critical Habitat for the Threatened Arctic Ringed Seal

On December 3, 2014, the National Marine Fisheries Service (NMFS) published its proposed rule designating critical habitat for the threatened Arctic Ringed Seal (Phoca hispida hispida). (79 Fed. Reg. 71,714)....more

FCA has published a Consultation Paper on Regulatory fees and levies for 2015/16

On November 27, the Financial Conduct Authority (FCA) published for comment a consultation paper on its fees and levies as part of their annual cycle of fees consultation. ...more

Federal Reserve Board Seeks Public Comment on the Application of Enhanced Prudential Standards to General Electric Capital...

On November 25, the Federal Reserve Board (the “Board”) released proposed enhanced prudential standards and reporting requirements to be applied to General Electric Capital Corporation (“GECC”) and requested public comment on...more

Federal Trade Commission Seeks Comments on Proposed Changes to Used Car Rule

The Federal Trade Commission (FTC) recently announced that it is seeking supplemental public comments on proposed changes to its Used Motor Vehicle Trade Regulation Rule (Used Car Rule) and the Used Car Buyers Guide (Buyers...more

China Issues Draft Guidance on Multi-Regional Clinical Trials

On November 21, 2014, China Food and Drug Administration (“CFDA”) released a Draft Guidance on Multi-Regional Clinical Trials (Provisional) (“Guidance”) for public comments through December 21. The Guidance aims to set forth...more

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