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Exemptions Public Comment

Holland & Knight LLP

Trucking Industry Group Seeks to Conduct Drug Screening Utilizing Hair Testing

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The Federal Motor Carrier Safety Administration (FMCSA) has requested public comment on an application for exemption submitted by The Trucking Alliance that would allow trucking companies to use hair testing in addition to...more

Goodwin

U.S. Department of Labor Issues Proposed Amendment to QPAM Exemption

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On July 26, 2022, the U.S. Department of Labor (the “Department”) issued a proposal to amend prohibited transaction class exemption 84-14 (the “QPAM Exemption”) under ERISA. The QPAM Exemption currently allows a plan’s...more

Goodwin

FinCEN Proposes Rules Implementing Corporate Ownership Requirements Under Corporate Transparency Act to Fill Gaps in U.S....

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WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336 (CTA). ...more

DirectEmployers Association

OFCCP Week In Review: September 2021 #2

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition, they...more

Wiley Rein LLP

Five Key Takeaways From EPA’s Biotech PIPs Exemption Proposed Rule

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On October 9, the U.S. Environmental Protection Agency (EPA) published for public comment its long-awaited proposed rule to exempt from most requirements of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)...more

White & Case LLP

Permitted Finder Activities: SEC Proposes Long-Awaited Exemption

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Finders seeking to assist companies in raising capital are required to navigate an often cloudy path to determine whether the finder's activities and any compensation the finder would receive for its services would run afoul...more

Goodwin

Divided SEC Votes To Propose “Finder” Exemption From Broker Registration

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On October 7, 2020, the U.S. Securities and Exchange Commission (“SEC”) voted 3-2 to propose a conditional exemption (“Exemption”) to permit natural persons to engage in limited securities activities as “finders” on behalf of...more

Goodwin

Investment Firms Be on Alert: Antitrust Agencies Propose Changes that Would Increase HSR Filings

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The Federal Trade Commission and the Antitrust Division of the Department of Justice (the “Agencies”) recently proposed two changes to the Hart-Scott-Rodino (“HSR”) rules that, if implemented, will materially impact private...more

Skadden, Arps, Slate, Meagher & Flom LLP

FTC and DOJ Propose ‘Modernizing Merger Filing’ Rules

On Monday, September 21, 2020, the Federal Trade Commission (FTC) and Department of Justice (DOJ) jointly released two proposed rule changes to the Hart-Scott-Rodino (HSR) premerger filing requirements for acquiring parties....more

Dechert LLP

What Did the DOL Just “Rollover” (and Roll Out)? – “A Primary Basis” for Understanding the New Proposed ERISA Exemption and...

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The U.S. Department of Labor (the “DOL”) on June 29, 2020 issued a release (the “Release”) proposing an important new initiative for retirement accounts (“Plans”) that are subject to the Employee Retirement Income Security...more

Bennett Jones LLP

CSA Announces Amendments to Rules Applicable to At-The-Market Distributions

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On June 4, 2020, the Canadian Securities Administrators (CSA) published amendments to National Instrument 44-102 – Shelf Distributions (NI 44-102) and Companion Policy 44-102CP Shelf Distributions. Proposed amendments were...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Proposes to Expand Availability of 3.10(c)(3) Registration Exemption for Non-U.S. Commodity Pool Operators

Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides that non-U.S. commodity pool operators (CPOs) are exempt from registration if they solely operate non-U.S. commodity pools offered to...more

Best Best & Krieger LLP

Organic Waste Regulation Cost Impacts

CalRecycle Study Makes Recommendations to Local Agencies - The California Department of Resources Recycling and Recovery released a draft report of cost impacts to local agencies to implement Senate Bill 1383 and reduce...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Re-Proposes Rules To Implement Resource Extraction Payment Disclosure Requirements

On December 18, 2019, the U.S. Securities and Exchange Commission (SEC) voted in favor of proposing rules to implement the resource extraction issuer disclosure provisions in Section 1504 of the Dodd-Frank Act, which added...more

DirectEmployers Association

OFCCP Week In Review: December 2019

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition,...more

White & Case LLP

SEC Proposes Rule Amendments to Enhance Regulation of Proxy Advisers

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On November 5, 2019, the Securities and Exchange Commission (“SEC”) proposed amendments to the federal proxy rules that would enhance the SEC’s regulation of proxy advisory firms.1 The proposed amendments to Rules 14a-1,...more

Fenwick & West LLP

SEC Proposes Rules Targeting Proxy Advisory Firms

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The U.S. Securities and Exchange Commission has proposed amendments to the proxy solicitation rules, directly targeting proxy advisory firms (Release No. 34-87457). Consistent with the updated interpretative guidance the SEC...more

White & Case LLP

CFIUS: Proposed FIRRMA Regulations Define CFIUS's Expanded Jurisdiction and Mandatory Filing Requirements

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On September 17, the US Department of the Treasury issued comprehensive proposed regulations to implement the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). This alert describes key aspects of the proposed...more

Dechert LLP

SEC Publishes Concept Release on Harmonization of Securities Offering Exemptions; Comment Deadline Approaching

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The U.S. Securities and Exchange Commission published a concept release on June 18, 2019 (Release), seeking public comment “on ways to simplify, harmonize, and improve” the framework for exemptions from registration under the...more

Faegre Drinker Biddle & Reath LLP

Applications for Customs Duty Exemptions under the Miscellaneous Tariff Bill Are Due Soon

On August 27, the US International Trade Commission (USITC) published amended rules and procedures for the preparation and filing of Miscellaneous Tariff Bill (MTB) petitions and public comments. The new rules take effect on...more

Parker Poe Adams & Bernstein LLP

U.S. Labor Department Proposes Expanding Religious Exemptions for Federal Contractors

On August 15, the U.S. Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) issued proposed regulations that would expand some federal contractors’ ability to claim exemption from discrimination...more

White & Case LLP

SEC: Time to revamp securities offering exemptions

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SEC is seeking public comments in its concept release in an effort to simplify, harmonize and improve the existing exempt offering framework. On June 18, 2019, the Securities and Exchange Commission (the “SEC” or the...more

K&L Gates LLP

SEC Asks 138 Questions in Concept Release on Overhauling Securities Offering Exemptions

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On June 18, 2019, the U.S. SEC published a concept release (Release No. 33-10649) (the “Harmonization Release”) requesting comments on whether and how the U.S. regulatory framework for offerings of securities that are exempt...more

Bennett Jones LLP

Proposed Amendments to Rules Applicable to At-the-Market Distributions

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On May 9, 2019, the Canadian Securities Administrators (CSA) published for comment proposed amendments to National Instrument 44-102 – Shelf Distributions (NI 44-102) and Companion Policy 44-102CP Shelf Distributions (see CSA...more

Sheppard Mullin Richter & Hampton LLP

New Regulation Clarifies DMHC’s Position Regarding Knox-Keene Licensing

After a protracted comment period, the California Department of Managed Health Care (the “Department”) formally adopted its much anticipated “global risk” regulation (the “Regulation”), which will go into effect on July 1,...more

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