News & Analysis as of

Final Rules Comment Period

A&O Shearman

FCA Primary Market Bulletin No. 55

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The UK Financial Conduct Authority (FCA) has published issue 55 of its Primary Market Bulletin (PMB 55). In PMB 55, the FCA: (i) provides feedback on its consultation in PMB 53, finalises 44 technical and procedural notes,...more

Clark Hill PLC

Only Foreign Entities Need to Report Under the CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, issued a new interim final rule on reporting under the Corporate Transparency Act (CTA). The new rule drastically...more

Montgomery McCracken

Corporate Transparency Act No Longer Applies to Entities Formed in the U.S.

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On March 26, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a division of the United States Department of the Treasury, published in the Federal Register an interim final rule that substantially narrows the...more

McGlinchey Stafford

FinCEN Drops Interim Rule on Reporting for U.S. Companies, But It Ain’t Over ‘Til It’s Over

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Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more

Foley & Lardner LLP

DEA Buprenorphine Rule Delayed to December 31, 2025

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The U.S. Department of Health and Human Services (HHS) and the Drug Enforcement Administration (DEA) have postponed the effective date of the final rule regarding telemedicine prescribing of buprenorphine (the final...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Eliminates Reporting Obligations for U.S. Companies and U.S. Persons

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that significantly narrows the beneficial ownership information (“BOI”) reporting requirements under the Corporate...more

Akin Gump Strauss Hauer & Feld LLP

HHS, FDA Announce Multiple Initiatives on Food Safety, Quality and Compliance Fronts

In the past week, the U.S. Food and Drug Administration (FDA), in collaboration with the Department of Health and Human Services (HHS) announced three new initiatives related to food safety and food supply chain transparency....more

Morrison & Foerster LLP

The New CTA: Calling Foreign Reporting Companies Only

Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more

Venable LLP

Regulatory Freeze: FDA Pushes Back Effective Date of "Healthy" Nutrient Content Claim Rule

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On February 25, the Food and Drug Administration (FDA) announced a delay in the effective date for its final rule updating the criteria to use the "healthy" nutrient content claim on food labeling....more

Fenwick & West LLP

Understanding the DEA’s New Telemedicine Rules: FAQ for Healthcare Providers and Telehealth Companies

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The U.S. Drug Enforcement Administration (DEA) recently announced new rules that will impact telemedicine practices, especially concerning remote prescribing of controlled substances....more

Troutman Pepper Locke

NYC DCWP Further Delays Effective Date of Amended Debt Collection Rules

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In our previous post, we discussed the New York City Department of Consumer and Worker Protection’s (NYC DCWP) decision to delay the enforcement of the amended debt collection rules from December 1, 2024, to April 1, 2025....more

Conn Maciel Carey LLP

Biden’s OSHA Pushes Heat Illness Prevention Rule Close to the Finish Line

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On January 14, 2025, just six days before the transition from the Biden Administration to the second Trump Administration, OSHA closed the books on collecting public comments on the agency’s Notice of Proposed Rulemaking...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

Maynard Nexsen

SBA Publishes Major Rule Change: Heeding Input, the Administration Clarifies and Refines M&A-Related Rules to Ease Concerns

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In August, the Small Business Administration ("SBA") issued a proposed rule that included significant and sweeping changes to its regulations, including to its rules on joint ventures, mentor-protégé, HUBZones, and others....more

Bricker Graydon LLP

The Department of Labor is Looking to End Subminimum Wages for Individuals with Disabilities.

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On December 3, 2024, the Department of Labor (DOL) introduced a Final Rule to end an employer’s ability to pay individuals with disabilities subminimum wages under federal law....more

Holland & Knight LLP

State Department Finalizes ITAR Registration Fee Increases

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The U.S. Department of State's Directorate of Defense Trade Controls (DDTC) has finalized significant changes to the registration fees under International Traffic in Arms Regulations (ITAR). The Arms Export Control Act...more

Hinshaw & Culbertson - Consumer Crossroads

New York City Department of Consumer and Worker Protection Proposes Amendments to its Definition of "Debt Collector"

In November 2024, the New York City Department of Consumer and Worker Protection (DCWP) proposed additional amendments to its rules relating to debt collectors to clarify the definition of a "debt collector."...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2024

The CFPB has adopted a final rule to extend its oversight to the largest nonbank providers of digital consumer payment applications, including those that enable transfers from deposit accounts held at banks and other insured...more

McDermott Will & Emery

Are We There Yet? DoD Issues Final Rule Establishing CMMC Program

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The US Department of Defense (DoD) published a final rule codifying the Cybersecurity Maturity Model Certification (CMMC) Program. The final CMMC rule will apply to all DoD contractors and subcontractors that will process,...more

Maynard Nexsen

SBA Proposes to Amend its Negative Control Rule, Which Could Have Major Implications for Small Businesses and Minority Shareholder

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Recently, the Small Business Administration ("SBA") issued a proposed rule, which could significantly alter the status quo for permissible negative control. Impacted small businesses and their minority shareholders and...more

WilmerHale

PTAB/USPTO Update - July 2024

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USPTO Leadership - ..On June 3, the USPTO announced the appointment of Derris Banks as Regional Director of the USPTO’s Elijah J. McCoy Midwest Regional Office located in Detroit, Michigan....more

WilmerHale

PTAB/USPTO Update - May 2024

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On April 30, the USPTO announced a Request for Comments (RFC) seeking public feedback on how AI could affect USPTO evaluations on patentability, including what qualifies as prior art and the assessment of the level of...more

Sheppard Mullin Richter & Hampton LLP

Not an April Fools Joke – FAR Part 40 Final Rule Has Been Published

On April 1, 2024, the FAR Council published a new Final Rule that establishes FAR Part 40 – but without any new provisions of substance. This Final Rule becomes effective on May 1, 2024. Subsequently, the FAR Council...more

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

FTC Announces Open Commission Meeting to Vote to Issue Final Rule Banning Noncompetes

On April 16, 2024, more than fifteen months after issuing a notice of proposed rulemaking that would ban noncompetes and nearly a year after the comment period closed, the Federal Trade Commission (FTC) announced it was...more

Bradley Arant Boult Cummings LLP

It’s the Final Countdown – The Final PWFA Regs Are Here

It has been a long road to this point, but the final Pregnant Workers Fairness Act (PWFA) regulations are here. We first blogged in early 2023 about the PWFA, which became effective in June 2023, and again last August when...more

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