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FCC Delays Effective Date of TCPA Revocation of Consent Rules

Just days before the “reasonable methods” provision of the Federal Communications Commission’s (FCC) new consent regulations under the Telephone Consumer Protection Act (TCPA) was set to take effect on April 11, 2025, the...more

Expect Focus - Volume I, January 2025

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence - In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church &...more

SEC Commissioners on the Hunt for Materiality: Disagree on Cybersecurity Enforcement Actions

On October 22, 2024, Republican SEC Commissioners Hester Peirce and Mark Uyeda issued a joint dissent sharply criticizing charges brought against four companies for allegedly making materially misleading disclosures regarding...more

CPPA Advances New Privacy Rules for Businesses

The California Privacy Protection Agency (CPPA), at its board meeting on November 8, 2024, voted 4–1 to advance proposed regulations to a formal rulemaking. As currently drafted, these regulations would, among other things...more

California Privacy Protection Agency Announces Delete Act Enforcement Sweep

Keeping the season spooky for data brokers, the enforcement division of the California Privacy Protection Agency announced on October 30, 2024, that it is conducting a public investigative sweep of data broker registration...more

Expect Focus - Volume IlI, September 2024

Gone With the Wind? Closed-End Funds Risk Extinction - Shares of SEC-registered closed-end funds (CEFs) have long held significant potential advantages for some investors. For example, unlike shares of mutual funds...more

Consent West-Winds: The Dark Cloud of Dark Patterns

On September 4, the California Privacy Protection Agency, the agency responsible for enforcing the California Consumer Privacy Act (CCPA), issued an enforcement advisory on “dark patterns” and their inability to constitute...more

California Privacy Protection Agency Issues Dark Pattern Enforcement Advisory

On September 4, the California Privacy Protection Agency issued an enforcement advisory regarding “choice architectures that have the substantial effect of subverting or impairing a consumer’s autonomy, decision-making, or...more

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