Public Comment

News & Analysis as of

Ontario Ministry’s Expert Report Recommends Big Changes to Province’s Corporate Laws

On July 9, 2015, an expert panel convened by the Ontario Ministry of Government and Consumer Services (MGCS) released their final report (the Expert Report) containing many broad recommendations on how to modernize Ontario’s...more

Proposed Treasury Regulations Offer Guidance on Disguised Payments for Services

Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more

FHA Proposes 3-Month Limit for Lender Claims to File Single Family Insurance Claims

The Federal Housing Administration (FHA) recently announced a proposed rule change that would establish a deadline for lenders to file insurance claims and modify its current policy for reimbursements when foreclosure and...more

Modernizing and Coordinating the Regulatory System of Biotechnology Products

On July 2, 2015, the U.S. Office of Science and Technology Policy (OSTP) of the Office of the President issued a memorandum to initiate a process to coordinate, update and modernize the federal regulatory system governing...more

EPA Issues Draft GHG Analysis For Cottonseed Oil Feedstock In Biofuels

EPA is inviting public comment on its analysis of greenhouse gas (GHG) emissions from the production and transport of cottonseed oil feedstock used in the production of biofuels. The Federal Register notice also provides an...more

The DOL and the Proposed Fiduciary Rule: A Prediction

Public comments regarding the Department of Labor’s proposed new fiduciary rule were due and the process will continue. I have said all along that the Department of Labor (DOL) will get a new fiduciary rule in place...more

CMS Is Considering New Stark Exceptions to Promote Clinical Integration and Value-Based Payment – Submit Your Comments By...

CMS has proposed significant changes in the Medicare physician self-referral (typically referred to as the “Stark Law”) regulations, including new compensation exceptions and several clarifications and refinements of existing...more

Foes of the NJDEP $225 Million Settlement with Exxon Mobil Must File “Friend of the Court” Briefs Today

After denying their motions to intervene last week (see our coverage here), Judge Hogan issued a Scheduling Order that sets today as the deadline for the eight environmental organizations and State Senator Lesniak (D-Union)...more

White House Releases Proposed Precision Medicine Initiative Privacy Framework

Earlier this year, President Obama launched a high-profile “Precision Medicine Initiative” (PMI) to develop treatments, diagnostics, and prevention strategies tailored to the individual genetic characteristics of each...more

CMS Proposes to Establish Separate Payment for End of Life Planning Services

On July 8, 2015, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule that updates payment rates and related reimbursement and quality policies for physician services furnished under the Medicare...more

Charter/Time Warner Tout Benefits, Seek Approval of Merger in State and Federal Filings

Local Governments Can Protect Themselves and the Public By Filing Comments - Charter Communications, Inc., Time Warner Cable Inc. and Advance/Newhouse Partnership recently filed a public interest statement with the FCC...more

CFTC Requests Public Comment on Rule Amendment Certification Filing by Ice Futures

The Commodity Futures Trading Commission is requesting public comment on a certification of proposed rule amendments that were filed by ICE Futures U.S. Inc. Under the amendments, ICE Futures would base position limits...more

SEC Seeks Comment on Possible Enhancement of Audit Committee Disclosures

On July 1, the Securities and Exchange Commission published a concept release to seek public comment regarding the potential enhancement of audit committee disclosure requirements, particularly as such disclosure relates to...more

CFTC Requests Comments on Petition for Exemption from DCO Registration by OTC Clearing Hong Kong Limited

The Commodity Futures Trading Commission is requesting public comment on a petition for exemption from registration as a derivatives clearing organization (DCO) filed by OTC Clearing Hong Kong Limited. Under Section...more

CFTC Issues Proposed Rules Regarding the Cross-Border Application of its Uncleared Swaps Margin Requirements

On June 29, 2015, the Commodity Futures Trading Commission (“CFTC”) issued proposed rules (“Proposed Rules”) regarding the cross-border application of its proposed uncleared swaps margin rules issued last October. The...more

The SEC Considers Updating Audit Committee Disclosures

The SEC recently published a concept release seeking comment on the need for new audit committee disclosures. This follows on the heels of recent PCAOB pronouncements and proposals regarding audit engagement partner...more

SEC Proposes Rules on Compensation Clawback Policies

On July 1, 2015, the Securities and Exchange Commission (SEC) proposed rules relating to compensation clawback policies. The rules, if adopted, would implement the requirements of Section 954 of the Dodd-Frank Wall Street...more

CFPB Report Details Ongoing Challenges Between Servicemembers and Student Loan Servicers

On July 7, the CFPB released a report detailing the continued challenges military servicemembers experience related to the servicing of their student loans, particularly when trying to invoke certain rights granted under the...more

FFIEC Releases Cybersecurity Assessment Tool

On June 30, 2015, the Federal Financial Institutions Examination Council (“FFIEC”), an interagency body that prescribes principles and standards for the federal examination of financial institutions, released a Cybersecurity...more

Blog: SEC Issues Concept Release Regarding Potential Additional Audit Committee Disclosures

The concept release seeks public comment on possible new reporting requirements focused on the audit committee’s responsibilities with respect to its oversight of the independent auditor. As the release notes, SOX mandated...more

SEC Seeks Public Input on Exchange-Traded Product Trading Issues

Growth in the ETP industry has led the SEC to seek public comment on a variety of topics related to the listing and trading of ETP shares. On June 12, the US Securities and Exchange Commission (SEC) issued a release (the...more

Feedback Sought on Higher Loss Absorbency Requirement for Global Systemically Important Insurers; Additional Information Regarding...

The International Association of Insurance Supervisors (“IAIS”) recently requested comments from the public as part of its effort to finalize development of the Higher Loss Absorbency (“HLA”) requirement for global...more

China Publishes Revised New Chemical Notification and Registration Guidance for Public Comment

After over a year of review and revision, on June 25, 2015, the Chinese Ministry of Environmental Protection Solid Waste and Chemical Management Center (MEP-SCC) published the "Guidance for New Chemical Substance Notification...more

DOL proposes dramatic changes to FLSA overtime rules

In March of 2014, President Obama issued a presidential memorandum directing the secretary of labor to “update” and “modernize” the regulations under which the U.S. Department of Labor (DOL) manages the Fair Labor Standards...more

Expanding the Meaning of Debt Collector in Ontario?

On June 15, 2015, Ontario’s Ministry of Government and Consumer Services (Ministry) issued a consultation paper, “Strengthening Consumer Financial Protection,” (consultation paper) which, in addition to offering a discussion...more

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