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Read need-to-know updates, commentary, and analysis on Administrative Agency issues written by leading professionals.
Orrick, Herrington & Sutcliffe LLP

OCC and FDIC Rescind Old Guidance and Provide Eight Lending Points

On December 5, the OCC and FDIC rescinded the Interagency Guidance on Leveraged Lending issued in 2013 and the related FAQs from 2014, citing concerns that these documents were “overly restrictive and impeded banks’...more

Clark Hill PLC

PFAS in Products: Minnesota Adopts PFAS Reporting and Fees Rule

Clark Hill PLC on

After a two-year rulemaking process, on Dec. 8, 2025, the Minnesota Pollution Control Agency (“MPCA”) finalized a rule that, with very limited exemptions, imposes a first-of-its-kind reporting requirement on manufacturers of...more

Venable LLP

Congressional Relief from Indirect Cost Rate Caps for Grantees - Congress Signals a Viewpoint in the NDAA

Venable LLP on

Early this week, the House and Senate Armed Services Committees released the final negotiated language of the Fiscal Year 2026 National Defense Authorization Act (FY26 NDAA), which the House promptly passed on December 10. ...more

Venable LLP

FDA Takes Steps to Modernize Sunscreen Options

Venable LLP on

FDA has published a proposed administrative order to include bemotrizinol (BEMT) as an active ingredient in over-the-counter (OTC) sunscreen products under the U.S. sunscreen monograph. The list has remained largely unchanged...more

Parker Poe Adams & Bernstein LLP

Treasury Department Audit Effort Signals Continued Interest by Administration on Use of Small Business Contracting Programs

Last month, the U.S. Department of the Treasury launched a broad audit program that will review all preference-based federal contracts and task orders within the department and its bureaus — totaling roughly $9 billion in...more

WilmerHale

CFTC Announces Amendments to Rules of Practice and Rules Relating to Investigations

WilmerHale on

On December 1, 2025, Commodity Futures Trading Commission (the Commission or CFTC) Acting Chairman Caroline Pham announced a suite of changes to the Commission’s Rules of Practice and the Wells process outlined in the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Beltway Buzz - December 2025 #2

The Beltway Buzz™ is a weekly update summarizing labor and employment news from inside the Beltway and clarifying how what’s happening in Washington, D.C., could impact your business....more

Hogan Lovells

FDA Opens a CMS-linked Side Door: Use of Digital Health Devices Before Authorization Under the TEMPO Pilot

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The U.S. Food and Drug Administration (FDA) announced the Technology-Enabled Meaningful Patient Outcomes for Digital Health Devices Pilot, or “TEMPO pilot,” on December 5, 2025, alongside a Federal Register notice seeking...more

Orrick, Herrington & Sutcliffe LLP

Fed Updates Its Pricing for Payment Services

On December 4, the Fed announced the pricing for certain payment services provided by the Federal Reserve Banks, e.g., the clearing of checks, ACH transactions, instant payments, wholesale payment and settlement services,...more

Mayer Brown

Application du taux de marché à un prêt intragroupe par voie de réclamation

Mayer Brown on

Le Conseil d’Etat rend une décision sur une demande d’application de la règle dite du « taux de marché » prévue à l’article 212, I-a du Code général des impôts a posteriori sur réclamation du contribuable. Contrairement à...more

Orrick, Herrington & Sutcliffe LLP

Small Business Administration Orders All 8(a) Program Participants to Submit Financial Records for Fraud Review

On December 5, the U.S. Small Business Administration (SBA) announced it has directed all 4,300 firms participating in the 8(a) Business Development Program to submit financial records for the past three fiscal years. The...more

Hogan Lovells

UK FCA Consults on Rule Changes for Client Categorisation and Conflicts of Interest

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On 8 December 2025, the FCA published a consultation paper (CP) on client categorisation and conflicts of interest. This consultation will be of particular interest to wealth managers and investment firms, as it may enable...more

Nelson Mullins Riley & Scarborough LLP

New Bipartisan Bill Seeks to Expand Medicare ACO Assignment Rules

U.S. Senators Sheldon Whitehouse (D-RI) and John Barrasso (R-WY) have introduced bipartisan legislation to expand access to high-quality, coordinated health care. The ACO Assignment Improvement Act aims to increase...more

Orrick, Herrington & Sutcliffe LLP

NCUA Proposes First Set of Regulatory Changes Under ‘Deregulation Project’

On December 10, the NCUA announced the first round of proposed regulatory changes as part of its new “Deregulation Project,” an initiative to review and potentially revise agency regulations to reduce burden and eliminate...more

Mayer Brown

Bénéficiaire effectif et non-application d’un taux réduit de retenue à la source en présence de dividendes versés à une société...

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Le Tribunal administratif de Paris valide la remise en cause par l’administration fiscale du taux réduit de retenue à la source de 5 % prévu par la convention franco-luxembourgeoise en présence de dividendes versés à une...more

Orrick, Herrington & Sutcliffe LLP

Fed Requests Comment on the Future of Agency’s Check Services

On December 9, the Fed published an RFI in the Federal Register requesting public input on the future of the Fed’s check services. In its notice, the Fed will assess possible strategies for the future of checks, acknowledging...more

Orrick, Herrington & Sutcliffe LLP

CFPB Publishes Eight Notices on Reinstating OMB Requirements

On December 9 and 10, the CFPB published eight notices in the Federal Register requesting comment on reinstating OMB approvals for existing information collections. The CFPB invited comments as to whether the collection of...more

GeoDataVision

When Regulatory Relief is not Regulatory Relief

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There’s a lot of things in the world of bureaucratic regulations that don’t appear to make sense and can be downright funny and frustrating at times. For example, when I was in the state senate in Connecticut the Department...more

Skadden, Arps, Slate, Meagher & Flom LLP

White House Launches National Framework Seeking To Preempt State AI Regulation

On December 11, 2025, President Donald Trump signed an executive order (EO), “Establishing a National Framework for Artificial Intelligence,” meant to create a “minimally burdensome” unified regulatory approach to sustain and...more

Ropes & Gray LLP

Trump Attempts to Preempt State AI Regulation Through Executive Order

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Following several unsuccessful attempts to secure federal preemption of state artificial intelligence (“AI”) regulations through Congress, first, through the “Big Beautiful Bill,” and then as part of the National Defense...more

McDermott Will & Schulte

This Week in 340B: November 25 – December 1, 2025

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Find this week’s updates on 340B litigation to help you stay in the know on how 340B cases are developing across the country. Each week we comb through the dockets of more than 50 340B cases to provide you with a quick...more

McDermott Will & Schulte

Trending in Telehealth: October 2025 Recap

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Trending in Telehealth highlights monthly state legislative and regulatory developments that impact the healthcare providers, telehealth and digital health companies, pharmacists, and technology companies that deliver – and...more

Bass, Berry & Sims PLC

DMEPOS Suppliers Subject to 36-Month Rule for Change in Majority Ownership and Minimum Annual Surveys

Bass, Berry & Sims PLC on

Effective January 1, 2026, all Durable Medical Equipment, Prosthetic Devices, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers will be subject to the Centers for Medicare & Medicaid Services (CMS) 36-month rule...more

Baker Botts L.L.P.

President Trump Signs Executive Order 'Ensuring a National Policy Framework for Artificial Intelligence'

Baker Botts L.L.P. on

On December 11, President Trump signed an Executive Order on “Ensuring a National Policy Framework for Artificial Intelligence” (the “Order”). The stated policy of the Order is to “sustain and enhance the United States’...more

Allen Matkins

California Environmental Law & Policy Update 12.12.25

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Federal wildlife officials on Monday denied listing the Western Coast Chinook salmon as threatened or endangered under the federal Endangered Species Act....more

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