Rulemaking Process

News & Analysis as of

U.S. Department of Labor Proposes Pay Transparency Rule for Employees of Federal Contractors

On September 17, 2014, the U.S. Department of Labor Office of Federal Contract Compliance Programs (OFCCP) published a Notice of Proposed Rulemaking in the Federal Register to implement Executive Order 13665, which was signed...more

CFTC Votes to Re-Propose Margin Requirements for Uncleared Swaps

On September 17, 2014, the Commodity Futures Trading Commission (“CFTC”) voted to re-propose rules to impose initial and variation margin requirements on uncleared swaps entered into by swap dealers and major swap...more

A Busy Year for NHTSA Enforcement and Rulemaking

This promises to be one of NHTSA’s busiest years for enforcement and rulemaking activity. NHTSA is expected to continue its aggressive enforcement, sparked by GM’s massive ignition switch recall and the flood of follow-on...more

OFCCP Announces Another Proposed Rule: No More Pay Secrecy!

The Office of Federal Contract Compliance Programs announced that it will publish its Notice of Proposed Rulemaking on "pay transparency" in tomorrow's Federal Register and provided a link to the pre-publication version on...more

Wrap-Up of Federal and State Chemical Regulatory Developments (September 2014)

Health Activists' Petition Seeks Sunset Of CBI Claims: On August 21, 2014, six environmental health organizations filed a petition under Section 21 of the Toxic Substances Control Act (TSCA). The petition urges the U.S....more

PA Tax Law News - September 2014

In This Issue: - Sales Factor Sourcing of Services & Intangibles - Nonresident Limited Partners Liable for Personal Income Tax - PA Appeal Systems Changes Update - Personal Responsibility for...more

D.C. Circuit Upholds FERC's Order No. 1000

On August 15, 2014, the D.C. Circuit issued a per curiam decision rejecting challenges to the Federal Energy Regulatory Commission's Order No. 1000 rulemaking brought by certain petitioners, including state regulatory...more

FinCEN Proposes New Rule Requiring Identification of Beneficial Owners

This summer the Financial Crimes Enforcement Network ("FinCEN”) issued a notice of proposed rulemaking proposing a rule that, if adopted, would mandate that financial institutions require their legal entity customers to...more

PHMSA Proposes Regulations Claimed to Make Business Easier for Retailers and Transporters and Finalizes a Regulation that Could...

The Pipeline and Hazardous Materials Safety Administration (PHMSA) recently published two proposed regulations that may positively affect retailers and transporters, if implemented as proposed. In addition, PHMSA finalized a...more

Proposed Rules Published on Dodd-Frank Changes to Home Mortgage Disclosure Regulations

On August 29, 2014, the Bureau of Consumer Financial Protection (the “Bureau”) issued a proposed rule and request for public comment on changes to its Regulation C (Home Mortgage Disclosure) to implement changes to the Home...more

SEC Adopts Credit Rating Agency Reform Rules

On August 27, 2014, the SEC adopted new rules for credit rating agencies implementing 14 rulemaking requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). The new rules are designed...more

Infobytes Special Alert: FinCEN Publishes Long - Awaited Proposed Customer Due Diligence Requirements

On August 4, 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking ("NPRM") that would amend existing Bank Secrecy Act (“BSA”) regulations...more

Analysts’ Views On 2014 RFS

As previously reported, the U.S. Environmental Protection Agency (EPA) sent the final 2014 Renewable Fuel Standard (RFS) rule to the Office of Management and Budget (OMB) on August 22, 2014. Some sides speculate that OMB will...more

FRB Issues Proposed Rules to Repeal Regulation AA, as Required by Dodd-Frank

On Wednesday, August 27, the Board of Governors of the Federal Reserve System (the “Board”) published in the Federal Register proposed rules and a request for public comment to repeal its Regulation AA (Unfair or Deceptive...more

A uniform code for the debt buying industry?

Among the topics being examined by the CFPB in connection with its expected debt collection rulemaking are the debt collection practices of debt buyers....more

CPSC Poised to Ban High-Powered Magnet Sets

Although the final rule currently under consideration by the CPSC sets a performance standard for magnet sets, the practical effect of the new safety standard will be a ban on the future sale or distribution of powerful rare...more

Saudi Capital Market Authority Publishes Draft Rules for Qualified Foreign Financial Institutions Investment in Listed Shares

Following last month’s announcement by the Saudi Arabian Capital Market Authority (the CMA) of its proposal to permit participation by qualified financial institutions directly on the Kingdom’s stock exchange (the Tadawul),...more

FinCEN's Busy August Yields Noteworthy Anti-Money Laundering Developments

August was a busy month for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). Among other initiatives, FinCEN issued its long-awaited proposed regulations on customer due diligence (CDD)...more

The Shale Play Today - August 2014

In This Issue: - A Look Ahead - What's Next for 2014: With 125 days left in 2014, we find ourselves looking at What's Next for the oil & gas industry in the Marcellus and Utica Shale Plays. It has been an...more

Regulation AB II

The Securities and Exchange Commission today adopted final amendments related to Regulation AB that were first proposed in 2010.1 The changes address the offering process and disclosure and periodic reporting requirements for...more

D.C. Circuit Ruling Upholds New Ground Rules in Development of Electric Transmission Infrastructure

The Federal Energy Regulatory Commission's (FERC or "Commission") landmark regional electric transmission planning rulemaking, a multi-year effort by the Commission that has been met with vigorous opposition from some...more

FTC Seeks Public Comment on AgeCheq, Inc.’s Proposed Parental Consent Method under COPPA

The Federal Trade Commission announced Monday that it seeks public comment on a new verifiable parental consent method application proposed by AgeCheq, Inc., to enable apps, websites and advertisers to obtain parental consent...more

Orrick Technology IPO Insights for Q2 2014

Welcome to the inaugural issue of Orrick Technology IPO Insights, a quarterly publication highlighting trends in U.S. information technology company IPOs. We isolate technology companies in order to analyze and present...more

New York Extends Comment Period For BitLicense Proposal

This week, the New York DFS announced the extension of the comment period on its proposal to create a regulatory licensing framework for virtual currency companies, including a so-called BitLicense. Given the “significant...more

FinCEN Proposes More Extensive Customer Due Diligence Obligations

As part of the U.S. Treasury Department’s ongoing efforts to combat all forms of illicit financial activity, from terrorist financing and sanctions evasion to more traditional financial crimes (including money laundering,...more

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