News & Analysis as of

Comment Period

National Waterways Conference Requests More Time on Draft 408 Policy

by Downey Brand LLP on

The National Waterways Conference has submitted a letter in response to the notice published in the Federal Register on February 5, 2018, seeking comment on the draft Engineering Circular (EC) on 408 permissions. According...more

Proposed Changes to the Mortgage Call Report, Proposal 2018-1

by Ballard Spahr LLP on

The NMLS has requested comments to the proposed changes to the Mortgage Call Report (MCR) as contained in Proposal 2018-1. Examples of the proposed changes include, but are not limited to, the following...more

OCC Seeks Comments on SAFE Act’s MLO Information Collection Requirement

by Weiner Brodsky Kider PC on

The Office of the Comptroller of the Currency (OCC) recently published a notice and request for comment regarding the Secure and Fair Enforcement for Mortgage Licensing Act’s (SAFE Act) mortgage loan originator (MLO)...more

California Issues Revised Proposed Underground Gas Storage Regulations

by Stoel Rives LLP on

On February 12, 2018, the California Department of Conservation (“DOC”) issued a public notice announcing revisions to the text of the proposed regulations in the rulemaking for California Underground Gas Storage Projects. ...more

Protecting the conscience and religious beliefs of health care workers

by Bricker & Eckler LLP on

The Trump administration has created a new division within the U.S. Department of Health and Human Services (HHS) tasked with protecting the moral and religious beliefs of health care workers. ...more

DDTC and BIS Solicit Comments Regarding Controls over Explosives, Personal Protective Equipment, and Military and Intelligence...

• DDTC and BIS have published concurrent NOIs requesting public comments on the controls over the export and reexport of explosives, personal protective equipment, and military and intelligence electronics. (By volume and...more

Superior Court Rules Committee Proposes Amendments, Solicits Comments

The comment period for the Superior Court Rules Committee’s proposed amendments to Rules 9A and 9C is open until February 15. While most of the amendments to Rule 9A are merely intended to simplify and reorganize the rule,...more

NMFS Extends Comment Period on Western DPS of Steller Sea Lion

by Nossaman LLP on

On February 6, 2018, the National Marine Fisheries Service (NMFS) announced an extension of the public comment period for the 5-year review of the endangered Western Distinct Population Segment (DPS) of the Steller sea Lion...more

Befuddled by BYOD? The Sedona Conference Has a New Set of Principles to Guide You: eDiscovery Best Practices

by CloudNine on

Many organizations are permitting (or even encouraging) their employees to use their own personal devices to access, create, and manage company related information – a practice commonly referred to as Bring Your Own Device...more

CMS Considers 7-Day Limit on Initial Opioid Prescriptions under Part D

In a Draft Call Letter issued February 1, 2018, the Centers for Medicare & Medicaid Services (CMS) announced that it is considering a number of new strategies to address opioid overutilization within the Medicare Part D...more

Cal/OSHA Drafts Rules For The Marijuana/Cannabis Industry And Heat Illness Prevention In Indoor Places Of Employment

by Seyfarth Shaw LLP on

Seyfarth Synopsis: The California Division of Occupational Safety and Health (DOSH) recently held advisory meetings on the Agency’s draft rules for the Marijuana/Cannabis Industry and for the Heat Illness Prevention in...more

CFTC Proposes Interpretation to Address Cryptocurrency Delivery Questions

by Ropes & Gray LLP on

On December 15, 2017, the U.S. Commodity Futures Trading Commission (“CFTC”) issued its proposed interpretation of the term “actual delivery” in the context of virtual currency retail commodity transactions. Comments to the...more

Time Is Almost Up on Efforts to Delay Start of Maryland Paid Sick Leave

by Miles & Stockbridge P.C. on

Employers are abuzz about the upcoming start of the Maryland Healthy Working Families Act, which goes into effect this Sunday, February 11, 2018. Contrary to some local news reports, efforts to delay this bill have not yet...more

Was This Interim Final Rule More Final Than Interim?

by 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

CFPB seeks comment on its enforcement processes

by Ballard Spahr LLP on

The CFPB has issued a request for information that seeks comment on how the agency can best achieve meaningful burden reduction or other improvement in the processes it uses to enforce federal consumer financial law while...more

U.S. Department of Education Issues Guidance on Providing FAPE After Supreme Court Decision in Endrew

by Hogan Lovells on

In Endrew, the U.S. Supreme Court ruled in favor of a higher standard of education for children with disabilities, which then raised many fundamental questions about special education across the nation. What is required for a...more

CFPB Solicits Comments on CID Process

by Goodwin on

The Consumer Financial Protection Bureau (CFPB) has solicited comments to assist it to revise its current Civil Investigative Demand (CID) process. The “Request for Information Regarding Bureau Civil Investigative Demands and...more

CEQA Guidelines Update: California Natural Resources Agency Issues Notice of Proposed Rulemaking

by Miller Starr Regalia on

On January 26, 2018, the Natural Resources Agency issued a Notice of Proposed Rulemaking to the public regarding its proposed updates to the CEQA Guidelines; the Notice and related rulemaking materials are available for...more

CFPB Requests Comments on its CID Process

by Ballard Spahr LLP on

On January 26, 2018, the CFPB published a “Request for Information Regarding Bureau Civil Investigative Demands and Associated Processes” (“Request”) in the Federal Register. ...more

Client Alert: U.S. Department of Health and Human Services ("HHS") Delays Effective and Compliance Date for the Revised Common...

The Federal Policy for the Protection of Human Subjects, or the “Common Rule,” was originally published in 1991 and has been adopted and codified in separate regulations by HHS and 15 other federal departments and agencies. ...more

The VA Proposes Placing Responsibility for Issuing Eligibility Regulations with SBA

by Holland & Knight LLP on

This is the first blog post by Holland & Knight’s newest government contracts attorney; Mitchell Bashur. Mitchell focuses his practice on government contracts and has extensive experience with protests, small and...more

Natural Resources Agency Launches CEQA Guidelines Rulemaking

The Natural Resources Agency has initiated formal rulemaking for a comprehensive update to the California Environmental Quality Act Guidelines. The proposed CEQA Guidelines amendments are the most comprehensive update...more

HHS Takes Action to Protect Religious Beliefs and Moral Convictions

by Shipman & Goodwin LLP on

On January 19, 2018, the United States Department of Health and Human Services (“HHS”) announced its new policy entitled “HHS Takes Major Actions to Protect Conscience Rights and Life”. This policy initiative announced by HHS...more

Freedom of Information Code of Practice Consultation

by Hogan Lovells on

The Government is consulting on various revisions to the Code of Practice for public authorities on their obligations under the Freedom of Information Act 2000 (the “Act“). ...more

NYS DOL Extends Comment Period for Proposed Scheduling Regulations

by Hodgson Russ LLP on

As we previously reported on November 22, 2017, the New York Department of Labor proposed regulations that would revise the on-call and call-in pay requirements for most employers. The proposed regulations would impose new...more

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