Rulemaking Process

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President Obama’s Proposed Privacy Bill of Rights - Part 3: Who’s Covered

This week we have brought you a multi-part series analyzing the Obama administration’s proposed Consumer Privacy Bill of Rights, which would require greater transparency by businesses in their privacy practices, and grant...more

CFTC Reopens Comment Periods

On February 24, the CFTC submitted for publication in the Federal Register a notice reopening the comment periods for the two Position Limit rulemakings, in anticipation of questions and comments that may arise from the...more

Highlights From SEC Speaks 2015

Securities and Exchange Commission leadership and staff members addressed the public on February 20-21 at the annual “SEC Speaks” conference in Washington, D.C. Common themes among the numerous presentations included the...more

Payday loan rulemaking prediction: CFPB will issue proposal this summer

Isaac Boltansky of Compass Point has issued an estimated timeline for the CFPB’s payday loan rulemaking that includes a July 2015 expected date for the CFPB’s release of a proposed rule. Mr. Boltansky estimates that the CFPB...more

CFPB Expected to Issue New Overdraft Rules in July 2015

New rules on overdraft protections and fees are a top regulatory priority for the CFPB this year. In its Fall 2014 Rulemaking Agenda, the CFPB noted that they were, “continuing to research overdraft services and considering...more

California Launches Major Rulemaking to Amend Low Carbon Fuel Standard

I. LCFS Readoption - On February 19, 2015, the California Air Resources Board (ARB) will take feedback on proposed regulations implementing the readoption and updating of California’s Low Carbon Fuel Standard (LCFS),...more

"MSRB Issues Status Update on Draft Rule G-42"

Earlier this week, the Municipal Securities Rulemaking Board (MSRB) released an update on the status of Draft Rule G-42, which outlines the duties of non-solicitor municipal advisors. The MSRB indicated that it has further...more

Studies question value of expected CFPB payday loan limits

The CFPB’s payday loan rulemaking was the subject of a NY Times article this past Sunday which has received considerable attention. According to the article, the CFPB will “soon release” its proposal which is expected to...more

FTC touts partnership with CFPB in annual debt collection report

In the FTC’s 2014 annual letter to the CFPB summarizing the FTC’s debt collection activities, the FTC describes the CFPB as a “valuable partner” with whom the FTC anticipates an “even stronger [partnership] in the...more

DOGGR Letter to USEPA Proposes Rulemaking to Eliminate Oil and Gas Well Injection into Non-exempt Aquifers

On Friday, February 6, California’s Division of Oil, Gas, and Geothermal Resources (“DOGGR”) published a letter to the US Environmental Protection Agency (“USEPA”) addressing issues with California’s Class II Oil and Gas...more

Analysis of SBA's Proposed Rule to Create a New Mentor-Protege Program for All Small Businesses

On February 5, 2015, the U.S. Small Business Administration (“SBA”) released its longawaited proposed rule to establish a mentor-protégé program for all small businesses. See 80 Fed. Reg. 6618 (Feb. 5, 2015). Federal...more

EEOC Seeks to Improve Federal Sector Equal Employment Opportunity Complaint Process

WASHINGTON - The U.S. Equal Employment Opportunity Commission (EEOC) has issued an advance notice of proposed rulemaking (ANPRM) on the equal employment opportunity (EEO) complaint process in the federal sector, the agency...more

CMS, ONC Update Meaningful Use FAQ, Lay Groundwork for HIT Changes

CMS and the Office of the National Coordinator for Health IT (ONC) announced several policy developments last week relating to electronic health record (EHR) technology issues....more

CMS Plans Spring Rulemaking to Modify Meaningful Use Requirements

CMS has announced that it plans to issue regulations this spring to address provider concerns about the burden associated with compliance with Medicare and Medicaid Electronic Health Record (EHR) Incentive Program meaningful...more

The Advisor as Fiduciary - 2015, Vol. 2

This is my favorite topic. If you read my last post, you understand why I believe that acting in the spirit of "fiduciary" sets every advisory firm up for success, compliance and otherwise. One of the few remaining items in...more

Drone on Drones: Recent Crashes Raise Public Awareness of Security Threat From Drones

Two drone crashes in recent weeks have raised public safety concerns, as law enforcement and national security agencies grapple with how to prepare for — and respond to — illicit uses of unmanned aerial vehicles....more

EPA Seeking Small Business Input on Federal Plan for Carbon Emission Goals

Today the U.S. Environmental Protection Agency (EPA) announced that it will seek stakeholder input on the development of a federal plan for meeting the Clean Power Plan’s carbon emission goals. Earlier this month, the EPA set...more

Communications Network Transitions and Next Generation 911: What You Need to Know About the FCC’s Proposed New Federal Framework

As part of its unrealized effort to bring policy coherence to the migration of traditional switch-based telephone networks towards all IP-based architectures, the Federal Communications Commission (FCC) recently commenced a...more

Increasing Focus in Washington on Drone Privacy Issues

As we await Federal Aviation Administration (“FAA”) proposed rules regarding the operation of drones that weigh less than 55 pounds, other parts of the federal government appear poised to scrutinize the privacy issues...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

EPA Seeks Additional Comment on NPDES Electronic Reporting Rule, and Other Recent CWA Developments

EPA Seeks Additional Comment On NPDES Electronic Reporting Rule: On December 1, 2014, the U.S. Environmental Protection Agency (EPA) requested additional comment on the proposed National Pollutant Discharge Elimination System...more

Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions

Highlights of this edition of the Cozen O’Connor Aviation Regulatory Update include the FAA’s recent rulemakings involving New York area airport slots and safety management systems for U.S. Part 121 air carriers, developments...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

Legal Alert: Ring in the New Year with New Summary of Benefits and Coverage Requirements for 2015

On December 30, the Departments of Treasury, Labor, and Health and Human Services published a joint notice of proposed rulemaking modifying the Summary of Benefits and Coverage (SBC) final regulations issued in 2012. In...more

The CFPB issues proposed rules on prepaid products

After issuing an advanced notice of proposed rulemaking regarding general purpose reloadable cards in May 2012, the US Consumer Financial Protection Bureau (‘CFPB’) issued proposed rules on prepaid products in November 2014....more

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