News & Analysis as of

Disclosure Requirements

Mayer Brown

ESMA Publishes Final Report on Changes to MAR Inside Information Disclosure Rules

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On 7 May 2025, the European Securities and Markets Authority (ESMA) published its Final Report on, among other things, technical advice concerning EU Market Abuse Regulation (MAR) provisions that have been amended pursuant to...more

Benesch

FTC Ride-Hail Lawsuit Shows Renewed Interest in Subscriptions

Benesch on

Notwithstanding significant changes at the Federal Trade Commission (FTC) – including the removal of two of the five Commissioners, and the new appointment of Commissioner Mark Meador – the Commission has sent a clear message...more

Goodwin

Indiana Enacts Law Regulating Earned Wage Access Services

Goodwin on

Indiana has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more

Venable LLP

To Be or Not to Be...Discoverable: Third-Party Litigation Funders

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Should California courts permit litigants to conduct discovery into litigation funding, namely whether a third party is funding their adversary’s litigation efforts?...more

Troutman Pepper Locke

New Virginia Law Mandates Disclosure of Mandatory Fees in Consumer Transactions, Subject to Certain Exemptions

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On May 2, Virginia Governor Glenn Youngkin signed Senate Bill 1212 (SB 1212) into law, introducing new requirements and prohibitions under the Virginia Consumer Protection Act. Specifically, SB 1212 targets the disclosure of...more

Fox Rothschild LLP

Washington State May Ease Pay Transparency Rules

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Washington Gov. Bob Ferguson is considering a bill that would amend the state’s wage disclosure requirements in the Equal Pay and Opportunities Act (EPOA) and implement major changes regarding potential liability for...more

Fox Rothschild LLP

New CCPA Regs: Part 2: Consumer Requests

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For the second installment of this series on the new California Consumer Privacy Act (CCPA) Regs, we are looking at consumer request processes. One major eye opener: Tracker opt-outs must be immediate and you may not be...more

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

Perkins Coie on

Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more

Ropes & Gray LLP

FCA Pauses SDR Extension to Portfolio Managers Due to Industry Concerns

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The UK's Financial Conduct Authority (FCA) launched a consultation in April 2024 to explore whether the existing Sustainability Disclosure Requirements (SDR) framework – introduced for asset managers in November 2023 – should...more

Winthrop & Weinstine, P.A.

General Counsel Checklist: Tariffs and SEC Disclosures

As global trade tensions escalate following the Trump administration’s proposed sweeping tariffs on imports, public companies face renewed pressure to ensure that securities disclosures adequately capture evolving risks. The...more

DLA Piper

BE-10 Filing Required for US Companies with Ownership in Non-US Businesses: Due May 30, 2025

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The US Department of Commerce’s Bureau of Economic Analysis (BEA) conducts a mandatory BE-10 survey of US investments abroad every five years to produce key economic and statistical reports on the scale and effects of...more

Kelley Drye & Warren LLP

FTC Issues FAQs on Fees Rule, Affirms Rule to Become Effective Next Week

The FTC issued FAQs to answer common questions about its Rule on Unfair or Deceptive Fees and to provide a small entity compliance guide in connection with the Rule. The issuance of the FAQs affirms that the current FTC, led...more

BCLP

Proposed Amendments to the Colorado AI Act

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As the regulatory landscape for AI continues to evolve, Colorado is considering significant changes to its recently enacted AI Act....more

Pillsbury Winthrop Shaw Pittman LLP

The Ironic Impact of FinCEN’s New CTA Regulations on New York’s LLC Transparency Act

The NYS LLC Transparency Act (the “New York Act”) became law in January 2024 and takes effect on January 1, 2026. When in effect, it would require limited liability companies formed or qualified to do business in New York to...more

Skadden, Arps, Slate, Meagher & Flom LLP

Conflict Minerals Disclosures Due June 2, 2025

Conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than June 2, 2025.1 The conflict minerals disclosure rules and related guidance have remained at a...more

Alston & Bird

Carrots and Sticks Cross the Pond: The SFO’s New Corporate Self-Reporting and Cooperation Guidance

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The UK Serious Fraud Office (SFO) has issued new guidance to encourage companies to self-report suspected corporate criminal conduct and cooperate fully with investigations. Our transatlantic White Collar, Government &...more

Vedder Price

SEC Division of Corporation Finance Staff Issues Guidance on Crypto Assets

Vedder Price on

As previously summarized here, since SEC Commissioner Mark T. Uyeda was named Acting Chairman on January 21, 2025, the SEC has significantly shifted its approach to cryptocurrency regulation and enforcement actions, including...more

Hogan Lovells

SFDR Update: European Commission launches Call for Evidence on simplification of the Sustainable Finance Disclosure Regulation...

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On 2 May 2025, the European Commission launched a Call for Evidence to inform its impact assessment for the simplification and improved effectiveness of the Sustainable Finance Disclosure Regulation (SFDR). This the last of a...more

Holland & Knight LLP

Litigation Funding in Georgia: New Registration and Disclosure Requirements

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Georgia Gov. Brian Kemp on April 21, 2025, signed into law Senate Bills (SB) 68 and 69 – Georgia's headline-grabbing tort reform bills (the Tort Reform Package). Though much has been published about the Tort Reform Package's...more

A&O Shearman

FCA findings on international payment pricing transparency

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The UK Financial Conduct Authority (FCA) has published examples of good and poor practices following its review into international payment pricing transparency. Under the consumer duty, in line with the FCA's Handbook (PRIN...more

Proskauer - The Capital Commitment

ESG in 2025: Finding the Sweet Spot in a Complex World

With ESG regulation now well embedded across all major jurisdictions, the trend we see for 2025 is about increasingly sophisticated triangulation by private fund managers between the regimes that apply by default (such as...more

Foley & Lardner LLP

Is Your Company Prepared for the FTC’s Junk Fees Rule, Effective May 12?

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On May 5, 2025, the Federal Trade Commission (FTC or “the Commission”) published FAQs aimed at providing consumers and businesses with information regarding the agency’s Rule on Unfair or Deceptive Fees (the “Junk Fees Rule”...more

Wilson Sonsini Goodrich & Rosati

Corp Fin Updates CDIs on Rule 10b5-1

On April 25, 2025, the U.S. Securities and Exchange Commission’s Division of Corporation Finance (Corp Fin) updated its Compliance and Disclosure Interpretations (CDIs) relating to Rule 10b5-1 by issuing two new CDIs,...more

Mayer Brown

New Resolution Regulates the Operation of Areas and Facilities of Organized Ports

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National Waterway Transport Agency (ANTAQ) published on April 9, 2025, the Resolution No. 127/2025 (“Resolution 127”), regulating the operation of port areas and facilities located within the boundaries of organized ports....more

Oberheiden P.C.

FAQs: 144A Resales vs. Regulation D Private Placements

Oberheiden P.C. on

Rule 144A and Regulation D offer exemptions from federal securities registration requirements under the Securities Act of 1933. However, they apply to different situations, and overseas companies must follow distinct...more

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