News & Analysis as of

Proposed Rules Compliance Disclosure Requirements

Mayer Brown

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

Mayer Brown on

On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

Ruder Ware

Hello, Goodbye: CTA Enforcement Suspended

Ruder Ware on

The U.S. Department of the Treasury suspended enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. On Sunday night, the Treasury announced that U.S. citizens and domestic...more

Cole Schotz

CTA is Effectively on Pause (Again)

Cole Schotz on

On Thursday, February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any enforcement actions against companies based on the failure to file or update beneficial ownership information (“BOI”)...more

Hinshaw & Culbertson LLP

UPDATE: FinCEN Pauses Penalties for CTA Reporting Noncompliance and Signals Additional Changes

As discussed in our previous alert, in connection with the recent reinstatement of the Corporate Transparency Act (CTA) and its reporting obligations, FinCEN issued an announcement (the "Prior Announcement") extending the...more

PilieroMazza PLLC

Proposed Rule on Organizational Conflicts of Interest Signals Significant Changes for Contractors

PilieroMazza PLLC on

Organizational conflicts of interest (OCIs) should be front of mind for any federal government contractor. The mere presence of an OCI may cause contractors to reconsider which contracting opportunities to pursue, reshape...more

Snell & Wilmer

FARA's Pendulum: Shifts in Foreign Agent Regulation

Snell & Wilmer on

On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more

Paul Hastings LLP

The U.K.’s New Cryptoasset Regime—the FCA Releases Its First Consultation Paper on Market Abuse and the Admissions and Disclosure...

Paul Hastings LLP on

The Financial Conduct Authority (FCA) has released its first publication (DP24/4) on its future rules for U.K. cryptoasset market participants. This discussion paper seeks input on the FCA’s proposed rules for admissions and...more

ArentFox Schiff

Nasdaq Rule Change Lengthens Reverse Stock Split Notice Period

ArentFox Schiff on

Last November, Nasdaq proposed a rule change that would lengthen the notification period for companies conducting reverse stock splits from five business days to 10 calendar days. The rule change became effective immediately...more

Nossaman LLP

U.S. DOJ Proposes FARA Amendments to Narrow Exemptions for Commercial Lobbying

Nossaman LLP on

Background On Thursday, January 2, 2025, the U.S. Department of Justice (DOJ) published a notice of proposed rulemaking (NPRM) in the Federal Register to amend and clarify the Foreign Agents Registration Act (FARA), starting...more

Morgan Lewis

DOJ’s Latest Attempt at Modernizing FARA Signals Greater Focus on Compliance and Enforcement

Morgan Lewis on

Following a decade of increased enforcement of what has been considered an oft-confusing law, the Department of Justice recently published a Notice of Proposed Rulemaking proposing several changes to regulations implemented...more

Wiley Rein LLP

FAR Council Withdraws Rulemakings on Pay Transparency and Contractor Disclosure of Greenhouse Gas Emissions

Wiley Rein LLP on

WHAT: The Federal Acquisition Regulatory Council (FAR Council) announced this week that it is withdrawing two proposed rules. First, it withdrew a January 2024 proposed rule that sought to prohibit government contractors from...more

MoFo Employment Law Commentary (ELC)

FAR Council Withdraws “Pay Equity and Transparency” Proposed Rule

On January 8, 2025, the Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulation (FAR) Council withdrew a proposed rule that would have banned federal contractors and subcontractors from seeking or...more

Proskauer - Government Contractor Compliance...

FAR Council Withdraws Proposed Contractor Pay Inquiry and Transparency Rule

Effective as of January 8, 2025, the FAR Council has withdrawn a proposed rule that would have limited federal contractors from seeking and considering information about job applicants’ compensation history and required...more

Jackson Lewis P.C.

FAR Council Withdraws Proposed Federal Contractor Pay Transparency Rule

Jackson Lewis P.C. on

Citing limited time in the remaining administration and desire to focus on “other priorities”, the Federal Acquisition Regulatory Council announced its withdrawal of the pending proposed rule requiring federal contractors...more

Holtzman Vogel Baran Torchinsky & Josefiak

In Compliance: Holtzman Vogel's July 2024 Round-Up

Holtzman Vogel attorneys wrote on the Supreme Court's landmark Loper Bright decision earlier this month. The Court overruled its 1984 decision in Chevron v. NRDC that introduced the so-called "Chevron deference" principle...more

Proskauer - The Capital Commitment

A Tale of Two Regulators: The SEC and FCA Address AI Regulation for Private Funds

2023’s excitement for generative artificial intelligence (AI) prompted the SEC to respond on multiple fronts – stump speeches, rulemaking, new exam priorities and sweeps and previewing potential enforcement actions. SEC Chair...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding SEC’s Focus Amid Lack of Final AI Rules

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Mintz

The US Securities & Exchange Commission Targets AI on Multiple Fronts: AI Sweep Examination

Mintz on

My last note touched on a recent SEC rule proposal regarding Predictive Data Analytics, and a speech by Chair Gary Gensler highlighting a number of AI-related concerns. The SEC’s interest in the use of AI does not appear...more

Venable LLP

OMB Pre-Releases Much-Anticipated Rewrite of the Uniform Guidance

Venable LLP on

On December 26, 2013, the Office of Management and Budget (OMB) issued the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly referred to as the "Uniform Guidance"). The...more

Holland & Knight LLP

Summary and Early Analysis of New SEC Private Fund Rules

Holland & Knight LLP on

The U.S. Securities and Exchange Commission (SEC) on Aug. 23, 2023, adopted the long-awaited private fund rules (Private Fund Rules) under the Investment Advisers Act of 1940 (Advisers Act) as part of SEC Release No. IA-6383...more

White & Case LLP

SEC Adopts Final Private Fund Adviser Rules

White & Case LLP on

New rules are expected to have substantial impact on funds industry - On August 23, 2023, the Securities and Exchange Commission ("SEC") approved significant new rules applicable to advisers of private funds (the "Private...more

WilmerHale

SEC Makes Sweeping Changes to Private Fund Adviser Regulatory Regime: Mandates Quarterly Reporting, Restricts Preferential...

WilmerHale on

In a 3-2 vote on August 23, 2023, the Securities and Exchange Commission (“SEC” or “Commission”) adopted five new rules under the Investment Advisers Act of 1940 (the “Advisers Act”), collectively called the “Private Fund...more

Latham & Watkins LLP

SEC Adopts Significant Rule Changes for Private Fund Advisers

Latham & Watkins LLP on

On August 23, 2023, the Securities and Exchange Commission (SEC) adopted a final rule package (each a Rule, and together, the Rules) that modifies the regulation of private fund advisers under the US Investment Advisers Act...more

BCLP

SEC Adopts Long-Awaited Final Rules for Private Fund Advisers

BCLP on

On August 23, 2023, in a 3-2 vote, the U.S. Securities and Exchange Commission (the “SEC”) adopted new rules (the “Final Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”) primarily affecting investment...more

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