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Read need-to-know updates, commentary, and analysis on Administrative Agency issues written by leading professionals.
Axinn, Veltrop & Harkrider LLP

Axinn Antitrust Insight: FTC Announces Revised HSR Thresholds for 2026

Each January, the Federal Trade Commission announces the new thresholds for premerger notifications under the HSR Act, which are updated each year based on changes in the gross national product. This year’s updated thresholds...more

Husch Blackwell LLP

Don’t Cry for Me, OFCCP. The Truth Is, It Hasn’t Left Yet

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Eva Peron’s farewell song from “Evita” comes to mind as the Office of Federal Contract Compliance Programs (OFCCP or Agency) loses its authority and prepares to take its final bow. Aligning with the Administration’s efforts...more

Perkins Coie

Export Control Exemptions Facilitate US Defense and Sensitive Technology Trade With Australia and the UK

Perkins Coie on

In support of the defense partnership between Australia, the United Kingdom, and the United States, over the last two years, the U.S. Department of State and the U.S. Department of Commerce have taken significant steps to...more

Troutman Pepper Locke

OCC Proposes Rule to Clarify Scope of National Trust Bank Activities

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The Office of the Comptroller of the Currency (OCC) has issued a Notice of Proposed Rulemaking aimed at clarifying the permissible activities of national trust banks. The proposal seeks to amend chartering regulations to...more

Fox Rothschild LLP

Oral Argument Scheduled in Hazardous Substance Designation Litigation

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Following the completion of briefing in the challenge to EPA’s rule designating PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), oral argument has...more

Troutman Pepper Locke

D.C. Circuit Declines to Reconsider its Prior Order Restoring an Emergency Affirmative Defense for Emissions Violations Under the...

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On January 2, 2026, the D.C. Circuit declined to rehear en banc its prior order restoring the Clean Air Act’s (CAA) Title V affirmative defense to liability for excess emissions caused by emergency events. A group of...more

Mintz - Health Care Viewpoints

No 'Paws' in Oversight: Will New York’s Proposed Veterinary Transaction Review Law Take Effect in 2026?

In September 2025, the New York State Assembly introduced Assembly Bill A9042, which would require veterinary clinics to provide notice and undergo Attorney General review for certain “material change” transactions, such as...more

Proskauer - Employee Benefits & Executive...

Third Circuit Holds No Deference Due Where Administrator Fails to Articulate an Interpretation of an Ambiguous Plan Term

In most cases, denials of ERISA plan benefits by administrators who have been granted discretionary authority to interpret and apply the plan are reviewed under an abuse of discretion standard, and may only be reversed if the...more

Holland & Hart LLP

the buzz: 2025 Year In Review

Holland & Hart LLP on

As we reflect on the whirlwind that was 2025, we find ourselves cautiously optimistic about the path ahead for the cannabis industry. While the year brought both unprecedented federal action and intensifying challenges, we...more

King & Spalding

Federal Court Blocks HRSA’s 340B Rebate Model Pilot Program Pending Appeal

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UPDATE: On January 12, 2026, the federal government announced it would drop its appeal of Judge Walker’s order blocking implementation of the Pilot Program and return it back to HRSA for reconsideration. In a court filing...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Waters of the United States/Clean Water Act: Arkansas Farm Bureau Comments on the U.S. EPA Proposed Rule

The Arkansas Farm Bureau (“ARFB”) submitted January 5th comments to the United States Environmental Protection Agency and United States Corps of Engineers (collectively, “Corps”) on the proposed rule to revise the definition...more

Troutman Pepper Locke

FERC Terminates Au Train Hydroelectric Project License by Implied Surrender

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On December 29, 2025, FERC terminated the hydropower license for the 0.9-megawatt Au Train Hydroelectric Project (FERC Project No. 10856), located on the Au Train River in Alger County, Michigan (Termination Order). FERC...more

Jackson Lewis P.C.

State Department to Suspend Consular Immigrant Visa Processing for 75 Countries Starting 1.21.26

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The Department of State is expected to pause consular immigrant visa processing for nationals of 75 countries starting Jan. 21, 2026, according to multiple public reports. This development represents a significant expansion...more

Alston & Bird

FDA: Drug & Device Advisory | Frequentist or Bayesian? All Roads Lead to Smarter Trials with FDA’s New Bayesian Guidance

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Our FDA: Drug & Device Team analyzes the Food and Drug Administration’s new guidance on Bayesian approaches to innovative drug trials, providing greater clarity on how companies may design and conduct studies....more

K&L Gates LLP

President Trump Issues Executive Order Limiting Stock Buybacks and Dividends for Defense Contractors

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On 7 January 2025, President Donald Trump issued an executive order (EO) aimed at limiting and preventing certain large defense contractors from conducting stock buybacks, issuing dividends, and awarding executive...more

K&L Gates LLP

To Z or Not to Z? CFPB Clarifies the Regulation Z Treatment of Certain Earned Wage Access Products

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The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion (the 2025 Opinion), effective 23 December 2025, on whether earned wage access (EWA) products constitute “credit” under Regulation Z of the Truth in...more

Haynes Boone

What’s Happening with Warnings on Texas Food Labels?

Haynes Boone on

In 2025, Texas became the first state in the U.S. to enact a labeling mandate for foods containing any of 44 specified ingredients as part of Senate Bill 25 (SB 25), the Make Texas Healthy Again Act. To recap, SB 25 requires...more

Nossaman LLP

Signed, Sealed, But Not Delivered? Don’t Wonder About Taxes Under New Postal Service Rules

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Even in the digital age, most federal and many state agencies consider important documents (like tax returns) filed on time if the filer can prove the documents were mailed by the due date. The postmark (really, a stamp with...more

Foley Hoag LLP

Business Considerations Amid Hemp Product Policy Change

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In passing the Agriculture, Rural Development, Food and Drug Administration, and Related Agency Act, Congress closed the hemp loophole effective Nov. 12, 2026, sending shock waves through the estimated $30 billion national...more

Foley Hoag LLP - Environmental Law

There's No Such Thing as "Cost" Analysis or "Benefit" Analysis; There's Only Cost-Benefit Analysis

Earlier this week, the New York Times reported that the Trump administration plans to stop assigning dollar values to the human health benefits resulting from the imposition of national ambient air quality standards....more

Haynes Boone

MoCRA Update: FDA’s Draft Q&A on Cosmetics Recall Authority

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The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is considered the most significant expansion of the U.S. Food and Drug Administration’s (FDA) authority to regulate cosmetics since the enactment of the Food, Drug...more

Stinson LLP

Federal Reserve Board Seeks Comment on "Skinny" Master Account/Payment Account Prototype

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The Federal Reserve Board (the Board) has issued a Request for Information and Comment (RFI) on the development of a special purpose Reserve Bank account prototype, being referred to colloquially as a "skinny master account"...more

Nelson Mullins Riley & Scarborough LLP

Federal Legislative Update: Momentum Builds Around Medicare Site-Neutral Payment Policies

Washington policymakers are increasingly aligned around expanding Medicare “site-neutral” payment policies in 2026, a shift that would pay hospital outpatient departments the same rates as physician offices for a broader set...more

Alston & Bird

Health Care Week in Review | House Passes Three-Year Extension of ACA Premium Tax Credits; CDC Updates Childhood Immunization...

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Below is Alston & Bird’s Health Care Week in Review, which provides a synopsis of the latest news in health care regulations, notices, and guidance; federal legislation and congressional committee action; reports, studies,...more

Morgan Lewis

Final US Postal Service Rules on Postmarks May Complicate Taxpayer Filings for Some Filers

Morgan Lewis on

Recently finalized rules from the United States Postal Service seek to clarify that the date on a postmark does not “necessarily represent either the place at which, or the date on which, the Postal Service first accepted...more

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