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Recordkeeping Requirements Proposed Amendments

Dechert LLP

CFTC Finalizes Rule 4.7 Amendments, Defers Key Disclosure Requirements

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The CFTC has finalized portions of its proposed October 2023 amendments to CFTC Rule 4.7. The CFTC moved forward on: Raising the thresholds for qualification of certain investors in private funds commodity pool operators...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

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The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Dechert LLP

SEC Adopts First Major Amendments to Regulation S-P Since 2000

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Incident Response Plans and Written Information Security Programs Continue to be Essential and Will Need to Be Reviewed. Most sophisticated organizations currently have in place incident response plans. Those organizations...more

Jenner & Block

Client Alert: The SEC Expands Its Cybersecurity Oversight by Adopting Regulation S-P Amendments

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Earlier this month, approximately one year after releasing its proposed amendments to Regulation S-P, the SEC announced the adoption of final amendments to Regulation S-P, expanding the information protected, the policies and...more

Troutman Pepper

FTC Announces Amendments to Telemarketing Sales Rule

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On March 7, the Federal Trade Commission (FTC) announced a final rule updating recordkeeping requirements and extending the protections against misrepresentations of the Telemarketing Sales Rule (TSR) to businesses (Final...more

Hinch Newman LLP

FTC Implements New TSR B2B Protections and Proposes Rule on Tech Support Scams

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On March 7, 2024, the Federal Trade Commission announced a final rule extending telemarketing fraud protections to businesses and updating the rule’s recordkeeping requirements as a result of developments in technology and...more

Dechert LLP

SEC Expands Scope of Fund “Names Rule”

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The Securities and Exchange Commission recently adopted significant changes to Rule 35d-1 under the Investment Company Act of 1940 (Names Rule), as well as certain forms and disclosure requirements on September 20, 2023...more

Hinshaw & Culbertson - Consumer Crossroads

New York City Department of Consumer and Worker Protection Issues Proposed Amendments to its Rules Relating to Debt Collectors

In September, the New York City Department of Consumer and Worker Protection (DCWP) requested comment on proposed amendments to its rules relating to debt collectors, which could significantly change the requirements and...more

Troutman Pepper

NYC Department of Consumer and Worker Protection Proposes Amendments to Debt Collection Rules

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New York City’s Department of Consumer and Worker Protection (NYC DCWP) recently released a notice of proposed amendments to its debt collection rules. The proposed amendments are detailed, lengthy, and include expanded...more

Bradley Arant Boult Cummings LLP

Mississippi Half-Step Uptown Toodeloo: Department of Health Proposes Robust Revisions to Medical Cannabis Regulations

Those long-awaited proposed revisions to the Mississippi Department of Health’s medical cannabis program regulations dropped last Thursday afternoon. Thankfully, the department released a red-lined version, highlighting...more

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

California’s Workplace Violence Bill Heavily Amended for Virtually All Employers

On February 15, 2023, California State Senator Dave Cortese (D-15) introduced Senate Bill (SB) No. 553, which originally aimed to require the California Division of Occupational Safety and Health (Cal/OSHA) to adopt...more

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

OSHA Recordkeeping Proposal Would Expand the Ranks of Employers Required to Submit Injury and Illness Data

On April 7, 2023, the Occupational Safety and Health Administration (OSHA) submitted its latest injury and illness recordkeeping proposal to the Office of Information and Regulatory Affairs (OIRA). The proposed changes to the...more

Dechert LLP

SEC Proposes Robust Amendments to Regulation S-P

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At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted unanimously to propose rule amendments to Regulation S-P (Proposed Rule) and published an accompanying release (Release). The Proposed...more

Paul Hastings LLP

SEC Proposes New Cybersecurity Rule and Amendments

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On March 15, 2023, the SEC issued proposed amendments and a proposed rule addressing cybersecurity. Specifically, the SEC proposed Rule 10, which addresses cybersecurity risks, and proposed to amend Regulation SCI and...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

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The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Eversheds Sutherland (US) LLP

SEC proposes sweeping revisions to Advisers Act Custody Rule

On February 15, 2022 the US Securities and Exchange Commission (SEC) proposed sweeping changes to Rule 206(4)-2 (the Custody Rule) under the Investment Advisers Act of 1940 (Advisers Act), which would be redesignated as Rule...more

Seward & Kissel LLP

SEC Proposes New Oversight Requirements for Certain Services Outsourced by Investment Advisers

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The Securities and Exchange Commission (the “SEC”) has proposed new rule 206(4)-11 (the “Proposed Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”). If adopted, the Proposed Rule would require registered...more

Eversheds Sutherland (US) LLP

SEC proposes service provider oversight requirements for investment advisers

On October 26, 2022, the Securities and Exchange Commission (SEC) proposed new Rule 206(4)-11 under the Investment Advisers Act of 1940 (Advisers Act), which would prohibit SEC-registered investment advisers from outsourcing...more

Foley Hoag LLP

DOL Issues Proposed Amendment to QPAM Exemption

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The Department of Labor (“DOL”) recently issued a proposed amendment to prohibited transaction class exemption 84-14 (the “QPAM Exemption”). The QPAM Exemption permits an investment fund managed by a qualified professional...more

Lowenstein Sandler LLP

Plan Fiduciaries, Including Investment Advisers and Fund Managers, Take Note – U.S. Department of Labor Proposes Enhanced QPAM...

On July 26, 2022, the U.S. Department of Labor (DOL) released a proposed amendment to Prohibited Transaction Class Exemption 84-14, known as the Qualified Professional Asset “Manager” (QPAM) exemption. ...more

Fisher Phillips

OSHA Again Proposes that Employers Electronically Submit Workplace Injury Forms

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Federal workplace safety officials are once again proposing amendments to occupational injury and illness recordkeeping rules that would require certain employers to electronically submit injury and illness information to...more

Goodwin

Agencies Launch Digital Identity Tech Sprint

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In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more

Goodwin

SEC Proposes Alternative to “WORM” Books and Records Retention for Broker-Dealers and Security-Based Swap Entities

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On November 18, 2021, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to Rules 17a-4 and 18a-6 under the Securities Exchange Act of 1934 related to recordkeeping requirements for broker-dealers and...more

Morgan Lewis

SEC Proposes Amendments to Electronic Recordkeeping Requirements

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While the US Securities and Exchange Commission seeks to modernize electronic recordkeeping requirements in a technology-neutral manner, its proposed amendments are unclear as to the permissible use of the “cloud” or...more

Fisher Phillips

What You Need To Know About Kentucky OSHA’s Proposed Injury and Illness Reporting Rule Change

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The Kentucky Labor Cabinet’s Department of Workplace Standards released its proposed amendments to its injury and illness recordkeeping and reporting requirements on February 11, 2020. A public hearing on these amendments...more

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