News & Analysis as of

Proposed Rules Transparency

A&O Shearman

ESMA MiFIR review consultation package on derivatives transparency, package orders and CTP data

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The European Securities and Markets Authority (ESMA) has launched its consultation in relation to derivatives transparency, package orders, and input and output data for consolidated tape providers (CTPs). This is the fourth...more

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

Landmark Settlement in NCAA NIL Litigation: Federal Judge Approves Settlement Over NIL Recruiting Rules

On March 21, 2025, the U.S. District Court for the Eastern District of Tennessee made its preliminary injunction permanent and approved a settlement as it relates to the National Collegiate Athletic Association’s (NCAA) bylaw...more

MoFo Life Sciences

HHS Secretary to FDA: Consider Elimination of GRAS Self-affirmation Pathway

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On March 10, the U.S. Department of Health and Human Services (HHS) issued a press release emphasizing “radical transparency to make sure all Americans know what is in their food” and announcing that HHS Secretary Robert F....more

Akin Gump Strauss Hauer & Feld LLP

Is Self-Affirming GRAS Off the Menu?

United States Department of Health and Human Services (HHS) Secretary Kennedy recently directed the U.S. Food and Drug Administration (FDA) to consider rulemaking to revise its longstanding regulations and guidance governing...more

A&O Shearman

The end of the road for (most of) the FCA's transparency proposals

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Just over a year ago, the UK Financial Conduct Authority (FCA) found itself at the centre of strong industry and political feedback when it first published its controversial proposals to ‘name and shame’ firms that it had...more

Maynard Nexsen

HHS Abandons Public Comment Practices Under the Richardson Waiver

Maynard Nexsen on

On March 3, 2025, the Department of Health and Human Services (HHS), under Secretary Robert F. Kennedy Jr., officially announced the rescission of the Richardson Waiver, a policy in place since 1971 that required public...more

Tonkon Torp LLP

The Corporate Transparency Act – Penalties Suspended

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The Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025 that it will not issue any fines or penalties or take any other enforcement action for failing to file or update BOI reports by the current...more

Amundsen Davis LLC

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act

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The U.S. Department of the Treasury has announced plans to significantly reduce the number of entities that must report under the Corporation Transparency Act (CTA) In a press release dated March 2, 2025, the Treasury...more

Woods Rogers

Treasury Department Suspends Enforcement of the Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies

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The U.S. Treasury Department has suspended enforcement of the Corporate Transparency Act for all U.S. citizens and domestic reporting companies....more

Ruder Ware

Hello, Goodbye: CTA Enforcement Suspended

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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

Hogan Lovells

UK FCA “naming and shaming” proposals: the House of Lords steps in.

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The House of Lords Financial Services Regulation Committee (“FSRC”) has published a report on the Financial Conduct Authority’s (“FCA”) proposals to change its approach to announcing enforcement investigations, from...more

Paul Hastings LLP

DOJ Announces Significant Proposed Changes to Amend and Clarify FARA

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On December 19, 2024, the Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) intended to “update and clarify” the regulations under the Foreign Agents Registration Act (FARA). The proposed changes to...more

Groom Law Group, Chartered

This Week From the Hill (January 12 – 18, 2025)

Each week while Congress is in session, our Policy team delivers a key update to highlight a topical benefits, health, or retirement news item from the Hill, such as a newly introduced bill, a summary of a committee hearing,...more

Sheppard Mullin Richter & Hampton LLP

Key Proposals from the CY 2026 Medicare Advantage and Part D Proposed Rule

On November 26, 2024, the Centers for Medicare & Medicaid Services (“CMS”) released the contract year 2026 proposed rule for the Medicare Advantage (“MA”) program, Medicare Prescription Drug Benefit Program (“Part D”),...more

Ropes & Gray LLP

CMS Proposes Beneficiary Protection and Marketing Updates for Medicare Advantage and Part D Plans in 2026

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On November 26, 2024, Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule revising the Medicare Advantage (“MA”) Program (Part C), Medicare Prescription Drug Benefit Program (Part D), Medicare Cost Plan...more

Davis Wright Tremaine LLP

FINRA's Proposed Partial Amendments to the Securities Lending and Transparency Engine (SLATE) Program

Earlier this year, FINRA filed with the SEC a proposed series of rules requiring, for the first time, the reporting of securities loans and providing for the public dissemination of loan information through FINRA's Securities...more

Benesch

When “No Comment” Isn’t an Option: FMCSA Publishes Proposed “Broker Transparency” Regulation

Benesch on

The Federal Motor Carrier Safety Administration (“FMCSA”) issued a Notice of Proposed Rulemaking (“NPRM”) on November 20, 2024,titled Transparency in Property Broker Transactions (89 FR 91648). ...more

Holtzman Vogel Baran Torchinsky & Josefiak

FCC Regulation of AI-Generated Political Ads Could Go into Effect This Cycle 

By: Oliver Roberts and Jason Torchinsky On Thursday July 25, 2024, the Federal Communications Commission (FCC) announced that it will “move forward with a proposal to implement new AI transparency requirements.” The FCC’s...more

Sullivan & Worcester

Are the SEC’s Private Fund Advisers Rules Now Dead? No, but they are on Life Support

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The U.S. Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) has thrown a wrench into the gears of the U.S. Securities and Exchange Commission (the “SEC”) in its attempt to regulate those investment advisers that...more

Proskauer - Regulatory & Compliance

Notice of Proposed Rulemaking under the Bank Merger Act to Increase Transparency

The U.S. Office of the Comptroller of Currency (OCC) released a notice of proposed rulemaking (NPR) seeking to “increase the transparency of the standards that apply to the agency’s review of business combinations involving...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Venable LLP

New FAR Pay Equity Rule Puts Contractors Between a Rock and a Hard Place: How Can Federal Contractors Ensure Proposed Labor Rates...

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On January 29, 2024, the Biden administration announced a series of pay equity and transparency initiatives. One initiative comes in the form of a proposed rule to amend the Federal Acquisition Regulation (FAR) to (1)...more

Pillsbury Winthrop Shaw Pittman LLP

AI and the “G” in ESG

As artificial intelligence (AI) expands into virtually every industry, companies should consider AI’s potential impacts on corporate governance and internal controls. Companies should integrate AI thoughtfully to ensure...more

McDermott Will & Emery

ONC’s HTI-1 Final Rule Adopts New Health IT Certification Requirements

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On December 13, 2023, the US Department of Health and Human Services (HHS) Office of the National Coordinator for Health Information Technology (ONC) issued the Health Data, Technology, and Interoperability: Certification...more

Venable LLP

New Nursing Home Transparency Rules and Their Impact on Real Estate Owners

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There has been increasing government interest in obtaining ownership information with respect to the class of commercial real estate comprising nursing facilities. Specifically, the government is focused on nursing home...more

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