News & Analysis as of

Administrative Procedure Act Comment Period

Jones Day

The CFTC is Off to a Fast Start Under Acting Chairman Pham

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In a break from the typical acting agency chairman, Acting Commodity Futures Trading Commission ("CFTC") Chairman Caroline Pham has taken several significant actions, signaled several more, and set the agency on a path to...more

Foley Hoag LLP - Energy & Climate Counsel

Coming Soon? Rules for Co-Locating Data Centers and Generators in PJM

Some of the biggest questions—and opportunities—facing the electric power sector in 2025 revolve around data centers and how to power them. The U.S. Department of Energy projects that the share of the nation’s electricity...more

McGuireWoods Consulting

Department Of Health And Human Services Proposes Ending Public Comment For Grants And Contracts

On Feb. 28, 2025, the Federal Register listed a proposal to end mandatory public comment periods for the Department of Health and Human Services (HHS). This specifically relates to “agency management or personnel or to public...more

Kilpatrick

Trump Administration Rescinds CEQ NEPA Implementing Regulations and Directs Federal Agencies to Revise NEPA Implementing...

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The National Environmental Policy Act (“NEPA”) requires an in-depth evaluation of the environmental impacts of federal actions, including actions by the federal agency itself, through issuance of a federal permit to private...more

Nossaman LLP

Supreme Court Clarifies Requirement for Agencies to Respond to Public Comments on Proposed Rulemakings

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The week of June 23, 2024, in Ohio v. Environmental Protection Agency, the U.S. Supreme Court clarified in a 5-4 decision that if a federal agency fails to provide a reasoned response to comments raised during the rulemaking...more

Benesch

Is There a Shortcut to Cannabis Rescheduling?

Benesch on

In the next 2 months or so, the Drug Enforcement Agency (DEA) is likely to announce that it will reschedule cannabis under the Controlled Substances Act (CSA) from a Schedule I highly dangerous and addictive drug with no...more

Bass, Berry & Sims PLC

Fifth Circuit Requires SEC to Revisit Share Repurchase Disclosure Rules

Bass, Berry & Sims PLC on

On October 31, the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) issued an opinion finding that the U.S. Securities and Exchange Commission (SEC) violated the Administration Procedure Act when adopting recent...more

Jones Day

SEC Reopens Comment Period for Rule Proposing New Disclosures for Security-Based Swaps

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The Situation: The Securities and Exchange Commission ("SEC") has reopened the comment period for its proposed rule requiring public disclosure of security-based swap ("SBS") positions that exceed certain thresholds....more

Eversheds Sutherland (US) LLP

Federal Trade Commission proposes rule to ban noncompete agreements in employment contracts

On January 5, 2023, the Federal Trade Commission (FTC) proposed a New Rule to ban noncompete clauses, which “hurt workers and harm competition.” The FTC’s proposed new rule builds upon President Biden’s Executive Order on...more

Polsinelli

The IRS is Not Backing Down: Proposed Regulations Issued Regarding Abusive Tax Shelters Including Certain Syndicated Conservation...

Polsinelli on

Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more

Holland & Knight LLP

'Tis the Season … to Reopen Public Comment on SEC's Share Buyback Rule Proposal?

Holland & Knight LLP on

The SEC announced on Dec. 7, 2022, a second reopening of the public comment period for its proposed Share Repurchase Disclosure Modernization rule (Rule), first proposed on Dec. 15, 2021. The initial 45-day comment period was...more

Cozen O'Connor

NLRB Proposes New Joint Employer Standard, Requiring Mere “Indirect” Control

Cozen O'Connor on

On September 6, 2022, the National Labor Relations Board (NLRB or Board) issued a Notice of Proposed Rulemaking (NPRM) that would significantly broaden the standard for determining whether two employers are joint employers...more

McDermott Will & Emery

New York State Department Intends to Finalize Corporate Tax Regulations This Fall

Almost seven years after it started releasing draft regulations concerning sweeping corporate tax reforms that went into effect back in 2015, the New York State Department of Taxation and Finance (Department) has issued...more

Mayer Brown Free Writings + Perspectives

25 Associations Press US SEC for Longer Comment Periods, APA Compliance for Rulemakings

In an April 5, 2022 letter, 25 trade associations jointly criticized recent US Securities and Exchange Commission (SEC) rulemakings and requested that the SEC provide longer, more appropriate comment periods (and more...more

Womble Bond Dickinson

The Biden Administration Expands Staff Vaccination Requirement to All Medicare & Medicaid Participating Providers/Suppliers.

Womble Bond Dickinson on

The Biden Administration, through the Centers for Medicare and Medicaid Services (“CMS”) and via Interim Final Rulemaking (“IFR”), has expanded vaccination requirements in many health care settings. Effective November 5,...more

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

Beltway Buzz - July 2021 #4

Senate Committee Examines PRO Act. On July 22, 2021, the U.S. Senate Committee on Health, Education, Labor and Pensions (HELP) held a hearing entitled “The Right to Organize: Empowering American Workers in a 21st Century...more

Gibney Anthony & Flaherty, LLP

Judge Strikes Down Rules Restricting Visas for High-Skilled Foreign Workers

A federal judge in California struck down two Trump administration rules that substantially altered the H-1B visa program for temporary professional workers and increased wage obligations for businesses employing certain...more

Nossaman LLP

NEPA Rules Rewrite: Revised NEPA Regulations Designed to Influence Litigation

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This is the sixth in a series of eAlerts on revisions to National Environmental Policy Act (NEPA) regulations published in the Federal Register on July 16, 2020, by the Council on Environmental Quality (CEQ). The CEQ’s...more

Miles & Stockbridge P.C.

Maryland Board of Public Works Solicits Comments to Proposed Redraft of Maryland Tidal Wetland Regulations by January 31, 2020

For the first time in more than 30 years, Maryland’s wetland regulations will undergo a review and update, for which the Maryland Board of Public Works’ Wetlands Administration (“BPW”) is soliciting comments on or before...more

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

Beltway Buzz - October 2019 #2

Supreme Return. The Supreme Court of the United States kicked off its 2019 term this week with a few blockbuster oral arguments. On October 9, 2019, the Court heard oral argument in three cases concerning whether gender...more

Proskauer Rose LLP

Diversity Visa Lottery: Lawsuit over New Passport Rule

Proskauer Rose LLP on

On September 25, 2019, we reminded clients that the Diversity Visa Lottery would be open from October 2, 2019 to November 5, 2019 for Fiscal Year 2021. A lawsuit has been initiated in federal court challenging the new...more

Jones Day

California’s Efforts to Regulate ACOs Hit a Speedbump

Jones Day on

The Situation: On October 8, 2018, California's Office of Administrative Law ("OAL") rejected a regulation that the Department of Managed Health Care ("DMHC") proposed. The regulation would require accountable care...more

Akin Gump Strauss Hauer & Feld LLP

What's New In Washington - September 2018

Following a truncated August recess, the House and the Senate returned to Washington after Labor Day with a full plate of legislative items to address prior to the end of the fiscal year on September 30. That list includes...more

Allen Matkins

Was This Interim Final Rule More Final Than Interim?

Allen Matkins on

I in this post from July 2016, I took the Securities and Exchange Commission to task for adding Item 16 to Form 10-K as an "Interim Final Rule". As I then explained, Interim Final Rules constitute an end-run on the notice...more

Harris Beach Murtha PLLC

Update on Status of Entrepreneurial Parole Program for Foreign Entrepreneurs

On January 17, 2017, the Department of Homeland Security (DHS) published a final rule establishing a parole program for international entrepreneurs seeking to improve the ability of certain startup founders to remain in the...more

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