On January 30, 2026, the Commodity Futures Trading Commission (CFTC) issued Staff Letter 26‑03 (Staff Letter), providing clarity for swap market participants regarding the treatment of certain legacy swaps with two Morgan...more
Occupational Safety and Health Administration regulations require employers to record work related injuries and illnesses on the OSHA 300 log. ...more
In June 2025, the United States Department of Labor announced a planned expansion of its opinion letter program intended to increase compliance assistance across several agencies including OSHA. The initiative is intended to...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) published a January 14th Interpretive Letter clarifying the Hazardous Materials Regulations (“HMR”) applicable to cargo tanks. See Reference...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a December 22, 2025, Interpretive Letter the application of the Hazardous Materials Regulations (“HMR”) to the transportation of...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 7th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) to the term “surfactant”...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 6th Interpretive Letter clarification of the Hazardous Materials Regulations (“HMR”) applicable to the definition of a...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) sent a December 11th Interpretive Letter to DG Advisor addressing the application of the federal Hazardous Materials Regulations (“HMR”) to what is...more
The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) issued seven letters of interpretation the week of December 8, 2025, as part of the Trump administration’s renewed opinion-letter program. ...more
There has been much ado about compliance assistance from the United States Department of Labor (DOL) this year. With these expanded opportunities, employers should consider seeking guidance on application of OSHA standards to...more
Last week, federal regulators took several notable steps affecting digital asset markets. The Office of the Comptroller of the Currency (OCC) announced conditional approval of five national trust bank charter applications. It...more
On December 9, 2025, the OCC issued Interpretive Letter #1188 to confirm that national banks may engage in riskless principal crypto-asset transactions, including transactions in assets that are not securities. Riskless...more
On November 18, the OCC issued Interpretive Letter 1186 confirming that a national bank may, as an activity incidental to the business of banking, pay crypto-asset network fees to support otherwise permissible banking...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a September 30th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) to the preparation of shipping...more
The United States Environmental Protection Agency (“EPA”) issued a September 2nd interpretive letter addressing the definition of “Begin Actual Construction” in the Clean Air Act New Source Review (“NSR”) regulations....more
United States Environmental Protection Agency (“EPA”) Office of Resource Conservation and Recovery Deputy Director Andrew Baca transmitted an October 8th Interpretive Letter addressing issues involving wood treatment....more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) transmitted a September 30th Interpretive Letter clarifying the Hazardous Materials Regulations (“HMR”) applicable to the preparation of...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an August 7th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) to the transportation of...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) clarified in an August 12th Interpretive Letter the Hazardous Materials Regulations (“HMR”) applicable to emergency discharge control equipment for...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a July 15th Interpretive Letter the application of the Hazardous Materials Regulations (“HMR”) to intermediate bulk containers (“IBCs”). See...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a June 10th interpretive letter the application of Hazardous Materials Regulations (“HMR”) applicable to wet batteries...more
On June 12, the OCC issued Interpretive Letter 1185 confirming that national banks may use certain debt securities as collateral in repurchase (repo) agreements. In the letter, the OCC responded to a December 19, 2024,...more
A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more
The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more