News & Analysis as of

Rulemaking Process Exemptions

Eversheds Sutherland (US) LLP

SEC provides green light to new exemptive relief

The SEC recently issued a notice with regard to a new model of co-investment relief and issued the first exemptive order for multi-class relief to a private BDC. This legal alert discusses both new developments....more

Goldberg Segalla

EPA Introduces New Email Account for Regulated Community to Request Presidential Exemption

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The Environmental Protection Agency announced March 12 it set up an e-mail account allowing the regulated community to request a presidential exemption under Section 112(i)(4) of the Clean Air Act (“CAA”)....more

Vedder Price

SEC Grants One-Year Exemption from New Short Sale Reporting Requirements

Vedder Price on

On February 7, 2025, the SEC issued a one-year exemption from compliance with new Rule 13f‑2 under the Securities Exchange Act of 1934 and related reporting on new Form SHO. The SEC adopted Rule 13f-2 and the Form SHO...more

Cozen O'Connor

FinCEN Exempts US Entities and Persons from CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) adopted an interim final rule (Rule) exempting U.S. companies previously subject to the reporting requirements under the Corporate Transparency Act (CTA)...more

Davis Wright Tremaine LLP

Salary Thresholds for FLSA Exemptions Increase Again on January 1, 2025 – Despite Challenges to DOL Rule

Before the end of the year, employers will need to review the exempt status of their employees to ensure they are compliant with upcoming changes to federal law. The U.S. Department of Labor ("DOL") sets minimum wage,...more

Venable LLP

Executive Order to Prevent Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern

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On February 28, 2024, the Biden Administration issued Executive Order (EO) 13873, focused on restricting certain transactions involving Americans' personal data, as well as sensitive government data, to specific countries....more

Cozen O'Connor

SEC Votes to Harmonize and Improve “Patchwork” Exempt Offering Framework

Cozen O'Connor on

On November 2, 2020, the U.S. Securities and Exchange Commission (the SEC), by a 3 – 2 vote, amended certain rules under the Securities Act of 1933 (the Securities Act) in order to harmonize, simplify, and modernize the...more

Faegre Drinker Biddle & Reath LLP

FCC Proposed Rulemaking Presents an Opportunity to Reshape Some Existing TCPA Exemptions

Over the years, one of the biggest challenges many businesses face when assessing TCPA risks posed by a new calling or texting campaign has been determining whether the proposed use case can defensibly rely on one of the...more

Mayer Brown Free Writings + Perspectives

SEC Proposes Rule Changes to Exempt Offering Framework

On March 4, 2020, the Securities and Exchange Commission (“SEC”) proposed amendments to the current framework of registration exemptions and safe harbors. ...more

Burr & Forman

Proposed SEC Rule 195 Token Incubation Safe-Harbor

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SEC Commissioner Hester Peirce earlier this month proposed a draft SEC Rule 195 as a safe-harbor for developmental token offerings, providing a registration exemption for three-years to allow the token’s network to achieve...more

Seyfarth Shaw LLP

Final CFIUS Regulations Became Effective in February 2020

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February 13, 2020 was the effective date (the “Effective Date”) for final regulations issued by the U.S. Department of the Treasury (“Treasury”) on behalf of the Committee on Foreign Investment in the United States (“CFIUS”)....more

Seyfarth Shaw LLP

SEC Commissioner Peirce Proposes Three Year “Safe Harbor” For Tokens

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Seyfarth Synopsis: On Thursday, February 6, 2020, SEC Commissioner Hester Peirce proposed rules which, if certain conditions are met, would, for three years, exempt (1) the offer and sale of tokens from most provisions of the...more

Ballard Spahr LLP

Alaska Exempts Nonprofit Organizations From Mortgage Lender Licensing Requirements

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The Alaska Department of Commerce, Community, and Economic Development recently adopted amendments to its mortgage lending regulations to exempt bona fide nonprofit organizations from the licensing requirement....more

Cadwalader, Wickersham & Taft LLP

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

Mayer Brown Free Writings + Perspectives

SEC Approves FINRA Rule 5110 Amendments

Recently, the Securities and Exchange Commission approved FINRA’s proposed amendments to its Corporate Financing Rule, which are intended to modernize, simplify, and streamline the rule....more

Cohen & Gresser LLP

The SEC Proposes Amendments to the Accredited Investor Definition

Cohen & Gresser LLP on

On December 18, 2019, the SEC proposed amendments to its definition of “accredited investor” to add new categories of qualifying natural persons and entities able to participate in certain exempt offerings without specific...more

Seyfarth Shaw LLP

Updates for Employers on the California Consumer Privacy Act

Seyfarth Shaw LLP on

Seyfarth Synopsis: California’s Attorney General is drafting regulations that will shape employer obligations under the California Consumer Privacy Act....more

Robinson+Cole Data Privacy + Security Insider

CCPA Amendment Details to Consider

In delving deeply into the California Consumer Privacy Act (CCPA), the Amendments recently signed by the California Governor, and the proposed Regulations issued by the California Attorney General, there are some details that...more

Orrick, Herrington & Sutcliffe LLP

Tax Relief for Replacing LIBOR in Tax-Exempt Debt and Swaps

Many tax-exempt bonds and related hedges, such as interest rate swaps ("Exempt Instruments"), use a LIBOR-based interest rate. LIBOR is going away, and existing Exempt Instruments are going to have to be modified to replace...more

Orrick, Herrington & Sutcliffe LLP

SEC Proposes New Guidance on Role of Municipal Advisers in Private Placements

In response to the proliferation of direct placements of municipal securities with financial institutions over the past decade, the Securities and Exchange Commission (SEC) has proposed a regulatory change to clarify the role...more

Troutman Pepper Locke

California AG Releases Proposed CCPA Implementing Regulations

Troutman Pepper Locke on

On October 10, the California Attorney General released highly anticipated proposed regulations implementing the California Consumer Privacy Act (CCPA). The CCPA, which takes effect on January 1, 2020, provides California...more

Ballard Spahr LLP

Federal Banking Agencies Increase Transaction Value Appraisal Exemption

Ballard Spahr LLP on

As we previously reported, last November the FDIC, Federal Reserve Board and Comptroller of the Currency (the federal banking agencies) proposed a rule to implement a rural residential property appraisal exemption under the...more

Proskauer - California Employment Law

Employees Will Be Exempted from Most Requirements of the Amended California Consumer Privacy Act … For Now

In an effort to give consumers more control over the data businesses collect from and about them, the California legislature passed the California Consumer Privacy Act (CCPA) in 2018 (and amended it a few months later). The...more

Robinson+Cole Data Privacy + Security Insider

California CCPA Amendment Update: Here’s What Passed

The California legislature passed six amendments to the California Consumer Privacy Act (CCPA) that are on their way to Governor Gavin Newsom’s desk. The Governor has until October 13, 2019, to act on the amendments. ...more

Orrick, Herrington & Sutcliffe LLP

The End of the California Legislative Session: Which CCPA Amendments Passed?

With the January 1, 2020 effective date of the California Consumer Privacy Act (the “CCPA”) rapidly approaching, all eyes have been on the California legislature’s consideration of a robust suite of amendments that would...more

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