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

Congressional Research Service Report Details CFPB Budget Trends, Funding Disputes, and Policy Options

On December 5, the Congressional Research Service (CRS) released a report analyzing the CFPB’s budget, funding trends, and related policy issues. The report reviewed the CFPB’s unique funding structure, which relies on...more

Hogan Lovells

EU Pharma Law Package: Council and Parliament Reach Agreement

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On 11 December 2025, the Council and the European Parliament reached agreement on the EU Pharma Law Package, also known as the General Pharmaceutical Legislation. No text has been published yet. The agreement will need to be...more

Orrick, Herrington & Sutcliffe LLP

OCC Issues Updated Venture Lending Guidance, Clarifies Risk Management Expectations

On December 5, the OCC issued updated guidance for banks on “venture loans” — commercial loans to companies in early, expansion or late stages of corporate development — rescinding its November 2023 bulletin of the same name...more

Nossaman LLP

What the Court Decision Invaliding the Federal Wind Energy Moratorium Means for Renewable Energy

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In a highly anticipated decision, the moratorium on permitting wind energy projects that federal agencies have imposed since January 20, 2025 was struck down by the Massachusetts Federal District Court on December 8, 2025....more

Orrick, Herrington & Sutcliffe LLP

OCC Releases CRA Evaluation Schedule for First Two Quarters of 2026

Recently, the OCC released its schedule of CRA evaluations to be conducted in the first and second quarters of 2026. The agency encouraged public comment on the CRA-related activities of national banks and federal savings...more

Haynes Boone

Mexico Alert: Inspection Protocol Applicable for Subcontracting Matters

Haynes Boone on

On Nov. 24, 2025, the Secretariat of Labor and Social Welfare (the STPS) published the Inspection Protocol Applicable for Subcontracting Matters (the Protocol), which sets out the procedure and indicators applicable to...more

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On December 5, the OCC and FDIC rescinded the Interagency Guidance on Leveraged Lending issued in 2013 and the related FAQs from 2014, citing concerns that these documents were “overly restrictive and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

Mayer Brown on

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

GeoDataVision on

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

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