Enforcement Relief: What New Regulatory Reforms Could Mean for Hospices
On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more
Under the University and Small Business Patent Procedures Act of 1980 (35 U.S.C. §§ 200-212), commonly referred to as the Bayh-Dole Act, the federal government can exercise “march-in” authority in certain circumstances to...more
The Federal Trade Commission (FTC) gave privacy lawyers a long-awaited Christmas gift on December 20, 2023: its notice of proposed rulemaking (NPRM) to amend the Children’s Online Privacy Protection Act (COPPA) Rule. The NPRM...more
The U.S. Copyright Office is seeking public comment on its proposal to create a group registration option for “frequently updated news websites.”...more
The Federal Trade Commission (FTC or Commission) received 105 comments from the public on its proposed trade regulation rule to prohibit marketers from using unfair or deceptive practices involving consumer reviews and...more
On November 3, 2023, the Commodity Futures Trading Commission (“CFTC”) proposed to significantly amend the rules on investment of customer funds by futures commission merchants (“FCMs”) and derivatives clearing organizations...more
On October 10, Governor Newsom signed the Delete Act ( SB 362) into law, which amends California's current data broker law to impose extensive additional disclosure and registration requirements on data brokers, and to...more
In the Byzantine complexity of the Clean Air Act (CAA), EPA’s “once in, always in” policy regarding hazardous air pollutants (HAP) has been particularly confounding. And now it’s back in play, through regulatory revisions...more
The Federal Trade Commission (FTC) and Department of Justice (DOJ), Antitrust Division announced that they will hold three workshops regarding their jointly issued Draft Merger Guidelines. The first virtual workshop will be...more
On June 12, the Federal Trade Commission (FTC or Commission) published a request for public comment seeking comments and suggestions on effective coordination efforts with state attorneys general nationwide to help educate...more
On May 31, 2023, the Federal Trade Commission (“FTC”) requested public comment on a petition for rulemaking it received from six national consumer advocate groups regarding “yo-yo sales,” a term the groups use to refer to...more
On April 13, 2023, the United States Fish and Wildlife Service (“Service”) published a proposed rule to revise the critical habitat designation for the rufa red knot (Calidris canutus rufa). The red knot is a shorebird that...more
It has been busy at the FCC. On March 16, 2023, the Federal Communications Commission (FCC or Commission) announced its issuance of two headline-making Report and Order and Further Notices of Proposed Rulemaking (FNPRM)...more
Many health tech and digital health companies offer subscription or membership services to clients and patients on an auto-renewal basis. Under this model, a subscriber’s credit card is automatically charged on a monthly,...more
The U.S. Food and Drug Administration (“FDA”) has announced its first-ever draft guidance specifically addressing the use of artificial intelligence/machine learning (“AI/ML”) in medical devices (“Draft Guidance”).This...more
The U.S. Food and Drug Administration (FDA) has published updated draft guidance for industry, Electronic Systems, Electronic Records, and Electronic Signatures in Clinical Investigations–Questions and Answers (Draft...more
The National Labor Relations Board (the Board) released its notice of proposed rulemaking (Proposed Rule) to establish a new “joint employer” legal standard under the National Labor Relations Act (NLRA) on September 6, 2022....more
The Department of Transportation (DOT) recently published a notice in the Federal Register of proposed rulemaking (NPRM) to amend the Disadvantaged Business Enterprise (DBE) and the Airport Concession Disadvantaged Business...more
On October 18, 2022, the U.S. Fish and Wildlife Service (Service) announced 12-month findings on a petition to list three California-based salamander species under the Endangered Species Act (ESA): the Kern Plateau salamander...more
Do you know which workers are your employees? That answer may change if a new rule proposed by the National Labor Relations Board (NLRB) takes effect. Last month, the NLRB issued a Notice of Proposed Rulemaking on the...more
For the magnificent ramshorn (Planorbella magnifica), a fresh-water snail species native to southeastern North Carolina, efforts to secure protection under the federal Endangered Species Act have progressed at a snail’s pace....more
By the time the comment period closed on June 17, 2022, the SEC had received thousands of comment letters from the public in response to the SEC’s proposed climate disclosure rules (the “Proposal”), which is perhaps the most...more
On May 19, 2022, the U.S. Department of Commerce (Commerce) published a Request for Comment titled “Developing a Framework on Competitiveness of Digital Asset Technologies” (Request for Comment). Digital assets, in this...more
On May 25, 2022, the U.S. Securities and Exchange Commission, by a vote of three-to-one, proposed for public comment amendments to a current rule governing fund naming conventions – which would cover certain funds that...more
On May 25, 2022, the U.S. Securities and Exchange Commission, by a vote of three-to-one, proposed for public comment a long-anticipated framework requiring certain funds and certain U.S. investment advisers to disclose their...more