As most employers are aware, last year the National Labor Relations Board (NLRB or “the Board”) published its final rule on joint employer status (the “Final Rule”). The Final Rule focuses on shared control, including...more
With the entry into force of its new Consumer Duty now only months away, the FCA has taken the opportunity presented by its latest Business Plan to reinforce its message that it’s placing ensuring good consumer outcomes at...more
On July 5, 2022, the Commonwealth of Massachusetts re-extended the implementation and enforcement date for the “Patients First Act”, sometimes referred to as the Massachusetts No Surprises Act, to January 1, 2025. As...more
New legislation to bring Guernsey into line with other jurisdictions on protecting Islanders from discrimination in and out of the workplace has been published, ahead of a planned States debate in September and implementation...more
DAC6 summary - Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more
Britain’s Prime Minister, Boris Johnson, secured victory in the December 2019 general election with a promise to “get Brexit done.” The UK duly left the European Union (EU) on 31 January, 2020, and the UK and the EU have...more
Eric Knickrehm discusses the important changes the proposed Physician Fee Schedule rule would have on Medicare Part B. Provided below is an overview of the most important aspects of the proposed rule, which was published...more
Seyfarth Synopsis: On June 13, 2019, Governor Baker signed into law S 2255, officially delaying the start of the payroll deductions for the Massachusetts Paid Family and Medical Leave (PFML) program by three months to...more
Economic sanctions, in one form or another, have been applied for centuries to effect change in the activities or policies of states, groups or individuals. Sometimes they are perceived as geopolitical economic weaponry,...more
The U.S. Department of the Treasury’s report on asset management and insurance recommends, among other things, a delay in implementation of the SEC’s liquidity risk management rule and the Department of Labor’s fiduciary...more
The New York Stock Exchange (“NYSE”) is seeking to delay the implementation of its recently-adopted dividend notification requirements until no later than February 1, 2018....more
On August 9, 2017, the Department of Labor (DOL) and Secretary of Labor, Alexander Acosta, submitted a proposal to the Office of Management and Budget (OMB) to further delay the applicability date of certain parts of the...more
The U.S. Department of Labor has moved to delay implementation of three exemptions of the “fiduciary rule” until July 2019. The regulation, which partially went into effect earlier this year, requires financial advisers to...more
Late last month, the Federal Occupational Safety and Health Administration (OSHA) announced a proposed delay for implementation of its new injury and illness reporting requirements until December 1. The rule originally was...more
Implementation Date - The first phase of the DOL’s fiduciary rule is scheduled to be implemented on June 9, 2017. ...more
Implementing the DOL Fiduciary Rule - Background - On June 9, 2017, key provisions of the fiduciary rule adopted by the Department of Labor (“DOL”) will become applicable for most broker-dealers, as well as many...more
The first phase of the Department of Labor’s (“DOL”) new fiduciary rule (“Fiduciary Rule”) is scheduled to be implemented on June 9, 2017. The Fiduciary Rule greatly expands the categories of persons who are deemed...more
This edition of the Cozen O’Connor Maritime and Infrastructure Federal Update discusses (i) the Jones Act conflict developing before Customs and Border Protection with respect to the use of foreign flag vessels to perform...more
On 10 March 2017, France finally implemented into French law the EU Directive 2014/104 of 26 November 2014 on antitrust damages actions. The implementation provisions faithfully transpose the Directive, but some concepts...more
The U.S. Department of Labor (“DOL”) issued a Field Assistance Bulletin (FAB 2017-01) on Friday, March 10, 2017 to address near-term compliance concerns relating to a proposed 60-day delay of the Fiduciary Rule. As previously...more
On December 15, 2016, the Office of Foreign Assets Control (“OFAC”) in the Department of the Treasury amended its Frequently Asked Questions guidance document (“FAQs”) regarding the Joint Comprehensive Plan of Action...more
On October 5, 2016, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited final rule to further regulate prepaid card products, or “prepaid accounts” (the “Final Rule” or “Rule”). The Final Rule follows...more
The beginning of the year brought the arrival of “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA) and its potential for business opportunities in Iran that had been shut off for decades (See Jan. 22,...more
Privy Council clarifies the nature of arbitration clauses, but uncertainties about the clauses’ effect still remain. “Non-exclusive” arbitration clauses provide that disputes “may” be referred to arbitration (rather than...more
Below is a summary of developments since our previous update in March relating to European Union (“EU”) sanctions on Iran, North Korea and other jurisdictions as well as highlights of recent changes with respect to the...more