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Read need-to-know updates, commentary, and analysis on Administrative Agency issues written by leading professionals.
Fox Rothschild LLP

Florida Severely Restricts Medical Marijuana Treatment Center Advertising and Marketing

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The rule adopts a restrictive framework under which anything not expressly permitted is prohibited. Its stated purpose is to ensure marijuana advertising remains medical in nature, factual, nonrecreational and not attractive...more

WilmerHale

JD Vance Announces New White House/DOJ Fraud Enforcement Initiative

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On January 8, Vice President JD Vance announced the creation of a new position at the Department of Justice (DOJ) to conduct fraud investigations as part of an “interagency” effort that would be “run out of the White House.” ...more

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

OSHAB Holds Stakeholders’ Roundtable on Procedural Changes and Improvements

On January 7, 2026, the California Occupational Safety and Health Appeals Board (Appeals Board or OSHAB) convened in Sacramento, California, for a stakeholders’ roundtable discussion to gather ideas for enhancing and...more

Sheppard Mullin Richter & Hampton LLP

What Employers Should Know About President Trump’s AI Executive Order

On December 11, 2025, President Trump signed an Executive Order titled Ensuring a National Policy Framework for Artificial Intelligence (the “EO”). This EO targets state laws addressing artificial intelligence and creates...more

Klein Moynihan Turco LLP

New Effective Date for TCPA Opt-Out Rule!

Although originally adopted on February 16, 2024, the Federal Communications Commission again has decided to delay the effective date of its opt-out regulation until January 31, 2027. We discuss the reasoning for the most...more

Troutman Pepper Locke

CFPB Complies with Court’s Funding Order in NTEU v. Vought

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On January 9, the defendants in National Treasury Employees Union (NTEU) v. Vought filed a notice and exhibit in the U.S. District Court for the District of Columbia confirming that the Acting Director of the Consumer...more

Perkins Coie

California Companion Chatbot Law Now in Effect

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Over the past several years, states have increasingly experimented with regulating how chatbots and other AI-driven conversational tools are used in consumer-facing contexts. Early efforts focused largely on transparency,...more

Bergeson & Campbell, P.C.

EPA Intends to Notify Companies Beginning in Spring 2026 of Expiring TSCA Claims

As reported in our September 12, 2025, blog item, under the 2016 Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) amendments to the Toxic Substances Control Act (TSCA), most confidential business...more

Orrick, Herrington & Sutcliffe LLP

OCC and FDIC clarify insider lending rules for banks and investment funds

On December 18, the OCC and FDIC issued a statement clarifying their supervisory expectations for banks regarding insider lending restrictions and related reporting requirements as they pertain to certain investment funds and...more

Morgan Lewis

New SEC Guidance Provides Regulatory Pathway for DTC Securities Tokenization Services

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The SEC staff issued a no-action letter on December 11, 2025 to the Depository Trust Company (DTC), a subsidiary of the Depository Trust & Clearing Corporation (DTCC) granting relief under certain provisions of the federal...more

Orrick, Herrington & Sutcliffe LLP

CFPB issues advisory opinion on the applicability of Regulation Z to earned wage access products

On December 23, the CFPB issued an advisory opinion in the Federal Register clarifying the regulatory treatment of earned wage access (EWA) products under Regulation Z, as implemented by TILA. ...more

Orrick, Herrington & Sutcliffe LLP

CFTC seeks public input on risks of direct clearing for retail derivatives clearing organizations

On December 18, the CFTC announced it had issued a request for comment to inform its understanding of the risks and regulatory issues related to derivatives clearing organizations (DCOs) that offer direct clearing services to...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Urgent! February Enforcement Date for Compliance with New 42 CFR Part 2 Rules Rapidly Approaching

With the February 16, 2026, compliance deadline rapidly approaching, health care providers that provide substance use disorder (SUD) treatment reimbursed by federal health care programs, including Medicaid, must ensure their...more

Clark Hill PLC

School Aid Act’s Section 164k Requirements and Federal Privacy Laws Intersect on Surveys | News & Events

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Section 164k of the State School Aid Act (MCL 388.1764k) was signed into law on Oct. 7, 2025, and requires schools to comply with certain legal requirements or face a 5% state aid penalty. ...more

Clark Hill PLC

Michigan Court of Appeals Holds No Definitive Timeline for Fulfilling FOIA Requests

Clark Hill PLC on

On Dec. 11, 2025, the Michigan Court of Appeals dismissed a complaint brought by the American Civil Liberties Union (“ACLU”) that challenged the amount of time public bodies have to fulfill records requests under the Michigan...more

Orrick, Herrington & Sutcliffe LLP

NCUA proposes second round of deregulatory reforms for credit unions

Recently, the NCUA announced a second round of proposed regulatory changes under its “Deregulation Project,” an ongoing effort to reduce regulatory burden and eliminate outdated or duplicative requirements....more

BCLP

FERC Directs PJM to Facilitate Faster Integration of Large Electric Loads, including Data Centers

BCLP on

In a much-anticipated order, on December 18, 2025, the Federal Energy Regulatory Commission (“FERC” or “the Commission”) ruled that existing rules for service applicable to generators serving co-located load and customers...more

Orrick, Herrington & Sutcliffe LLP

CFPB updates asset-size exemption thresholds under TILA and HMDA

On January 7, the CFPB amended the official commentary to Regulation Z (which implements TILA) and Regulation C (which implements the HMDA) by updating the asset-size exemption thresholds for financial institutions. These...more

Husch Blackwell LLP

False Claims Act Insights - The Rise of State False Claims Act Enforcement

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Host Jonathan Porter welcomes Husch Blackwell partners Rebecca Furdek and Todd Gee back to the podcast to discuss the growing amount of enforcement under various state-level False Claims Acts, and the recent Risk Management...more

Orrick, Herrington & Sutcliffe LLP

OCC expands its reach with two actions on escrow laws

On December 23, the OCC published two notices of proposed rulemaking in the Federal Register that would clarify and reinforce federal banking authorities over interest-on-escrow laws and real estate lending escrow accounts. ...more

Morgan Lewis

Counting the Days: Fifth Circuit Reverses Texas Hospitals’ DSH Rule Challenge

Morgan Lewis on

The US Court of Appeals for the Fifth Circuit on December 9, 2025 reversed and remanded a decision from the US District Court for the Northern District of Texas that had vacated a 2023 federal regulation that threatened to...more

Bergeson & Campbell, P.C.

OEHHA Issues Information Letters Providing Prop 65 Guidance

In December 2025, the California Office of Environmental Health Hazard Assessment (OEHHA), the state agency responsible for implementing Proposition 65 (Prop 65), issued two “Information Letters” regarding Prop 65 compliance...more

Kilpatrick

From Transparency to Oversight: New York’s RAISE Act Raises the Bar for Frontier AI Developers

Kilpatrick on

On December 19, 2025, New York Governor Kathy Hochul signed Assembly Bill A6453-A, the Responsible AI Safety and Education Act (RAISE Act), into law.The statute establishes a targeted framework governing the development and...more

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit upholds FHFA funding structure against constitutional challenge

On January 2, the U.S. Court of Appeals for the Ninth Circuit upheld the constitutionality of the FHFA’s funding mechanism, affirming the dismissal of a lawsuit that challenged the agency’s authority under the Appropriations...more

Mintz - Energy & Sustainability Viewpoints

Sustainable Energy & Infrastructure Litigation Updates — January 2026

New York State has imposed a mandatory greenhouse gas emissions reporting program that will require disclosure of 2026 emissions data in 2027...more

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