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Administrative Agency Securities

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

Protections Proposed for Monarch Butterfly

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On December 10, 2024, the U.S. Fish and Wildlife Service (Service) released its long-anticipated listing proposal for the monarch butterfly (Danaus plexippus), along with a proposed critical habitat designation and...more

Mayer Brown

In Brief: FinCEN Confirms Suspension of Corporate Transparency Act Filing Obligations During Nationwide Injunction

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On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the...more

Coblentz Patch Duffy & Bass

Corporate Transparency Act Blocked Nationwide by Texas Court

On Tuesday, December 3, 2024, a Texas federal judge granted a preliminary injunction halting the continuing implementation of the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting...more

Seyfarth Shaw LLP

FinCEN Acknowledges Nationwide Preliminary Injunction on CTA Enforcement – Voluntary Submission Only

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On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., blocking enforcement of the Corporate...more

Jones Day

The Climate Report | Fourth Quarter 2024

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New ESG regulations are expected to have a significant impact on disclosure and governance obligations for EU and non-EU companies alike, including extensive sustainability reporting and due diligence requirements on...more

Ballard Spahr LLP

HUD extends compliance date for portions of “Modernization of Engagement with Mortgagors in Default’’ rule

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The U.S. Department of Housing and Urban Development (HUD) has extended from January 1, 2025 until July 1, 2025, the compliance date for certain provisions of the department’s rule entitled “Modernization of Engagement with...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - December 2024 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

McDermott Will & Emery

Massachusetts Implements Long-Awaited Licensing Regime for Out-of-State Pharmacies

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Until recently, Massachusetts was the only state that did not maintain a licensing regime for nonresident pharmacies (i.e., out-of-state pharmacies shipping drugs into the state). On December 6, 2024, the Massachusetts Board...more

A&O Shearman

Implementing Regulation on Standard Templates for the Register of Information

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The European Commission rejected the European Supervisory Authorities' draft ITS in September on the basis that financial entities should have the choice of using either EU unique identifiers or legal entity identifiers. The...more

A&O Shearman

Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products

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On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...more

Troutman Pepper

Potential State-Centric Marijuana Policy in the 119th Congress

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With power changing hands in Washington, D.C., what can marijuana industry members expect from the 119th Congress? Two GOP proposals from the 118th Congress may foreshadow the likely path for federal marijuana legalization....more

A&O Shearman

DC Circuit Grants Preliminary Injunction Preventing FINRA From Expelling Member Without SEC Review, Finding Private Nondelegation...

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On November 22, 2024, the D.C. Circuit Court of Appeals enjoined the Financial Institution Regulatory Authority (“FINRA”) from expelling a member firm without Securities and Exchange Commission (“SEC”) review. Alpine...more

DLA Piper

Puerto Rico Department of Consumer Affairs Reactivates its Office Against Discrimination in Commerce

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The Puerto Rico Department of Consumer Affairs (DACO, per its acronym in Spanish) reactivated its Office Against Discrimination in Commerce (OADC) in September 2024 to ensure Puerto Rican consumers receive fair and equal...more

Bradley Arant Boult Cummings LLP

Cannabis & Trademarks: Protecting Your Stash

Trademark law protects businesses’ brand identities and helps prevent consumer confusion. The U.S. trademark system operates at both federal and state levels. Federal registration through the United States Patent and...more

Ballard Spahr LLP

CFPB Proposes Broad New Data Broker Rule That Would Greatly Expand the FCRA

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On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) published its long anticipated proposed rule aimed at regulating data brokers under the Fair Credit Reporting Act (FCRA).  Although the CFPB’s future is...more

A&O Shearman

Bank of England Consults on Revocation of UK Technical Standards on Simplified Obligations

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The Bank of England has published a consultation paper on the proposed revocation of the U.K. technical standards on simplified obligations. The U.K. retained the EU framework for determining the level of information required...more

Perkins Coie

Nationwide Injunction Against Corporate Transparency Act Enforcement: What To Know and What To Expect

Perkins Coie on

The U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the Corporate Transparency Act (CTA)...more

Akin Gump Strauss Hauer & Feld LLP

CFTC’S Year-End AI “Placeholder” Guidance

On December 5, 2024, the Staff of every market-facing division of the U.S. Commodity Futures Trading Commission (CFTC) issued a joint “Staff Advisory” on the use of artificial intelligence in CFTC-regulated markets and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Maine Residents Pass Ballot Measure Limiting Contributions to Super PACs; Changes to New York Lobby Filings Go Into Effect

Maine - On November 5, 2024, Maine residents voted in favor of passing a ballot measure that limits contributions from individuals, PACs and business entities to PACs “for the purpose of making independent expenditures” to...more

A&O Shearman

Zooming in on AI – #13: EU AI act– Focus on fundamental rights impact assessment for high-risk AI systems

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Companies deploying high-risk artificial intelligence (AI) systems must prepare to conduct Fundamental Rights Impact Assessment (FRIA) by 2 August 2026. In this edition of our “Zooming in on AI” series we explain what this...more

McDermott Will & Emery

Colorado Advances Privacy Act Regulations

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On December 5, 2024, the Colorado Department of Law (Department) adopted an amended draft of its latest proposed Colorado Privacy Act (CPA) regulations. This set of amended regulations follows a public comment period that...more

A&O Shearman

Transparency on Hold: FinCEN confirms a halt to Corporate Transparency Act reporting (for now)

A&O Shearman on

For the past week, millions of companies have been eagerly awaiting the Financial Crimes Enforcement Network’s (FinCEN) statement in response to the December 3, 2024 preliminary injunction that has halted enforcement of the...more

Woods Rogers

Corporate Transparency Act Enjoined: How should your company respond now?

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The reporting requirement of the Corporate Transparency Act (CTA) was preliminarily enjoined on December 3, 2024, by an Order of the U.S. District Court for the Eastern District of Texas. The Court issued a nationwide...more

Goldberg Segalla

EPA Announces Part 2 of Final Rule to Prohibit Asbestos Use in the United States

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The U.S. Environmental Protection Agency on Dec. 3 issued Part 2 of a final risk determination providing an overview of the hazards of asbestos “to workers in certain conditions.” The agency will soon begin the risk...more

Schwabe, Williamson & Wyatt PC

A More Modest Procedure? — The Supreme Court Considers Limiting the Scope of ‎‎“Reasonably Foreseeable” Impacts in NEPA Analysis

Seven County Infrastructure Coalition, et al. v. Eagle County, Colorado et al. ‎ On Tuesday, December 10, the Supreme Court heard arguments in a case that could redefine what constitutes a “reasonably foreseeable”...more

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