News & Analysis as of

Rulemaking Process Filing Deadlines

Husch Blackwell LLP

DOT Intends to Amend or Revoke 52 Transportation Regulations

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Recently, the Department of Transportation (DOT) announced its intention to implement 52 deregulatory actions across the Federal Highway Administration, Federal Motor Carrier Safety Administration, and National Highway...more

Miller Nash LLP

California Climate Disclosure Laws Will Go Into Effect Before California Air Resources Board Finalizes Regulations

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On May 29, 2025, the California Air Resources Board (CARB) hosted a virtual public workshop to discuss its progress in implementing California’s sweeping new climate disclosure laws. California Senate Bills (SB) 253, 261, and...more

Cooley LLP

SEC Issues Concept Release on Foreign Private Issuer Eligibility

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On June 4, 2025, following observation of the significant increase in the foreign private issuer (FPI) population between 2003 and 2023, the Securities and Exchange Commission (SEC) published a concept release soliciting...more

BakerHostetler

The Delayed, but Not Forgotten, Disclosure of PFAS: TSCA Section 8(a)(7) Postponed While States Fill the Gaps

BakerHostetler on

When Congress passed the fiscal year 2020 National Defense Authorization Act (“NDAA”), it included a mandate that the U.S. Environmental Protection Agency (“EPA”) take steps to require all manufacturers, including importers,...more

Troutman Pepper Locke

CARB Workshop on Climate Disclosure Laws: More Questions Than Answers

Troutman Pepper Locke on

On May 29, 2025, the California Air Resources Board (CARB) held a virtual public workshop to review and discuss its rulemaking response to California Senate Bills (SBs) 253, 261, and 219, which require companies that “do...more

Fox Rothschild LLP

Initial Concepts Provided on California Climate Disclosure Laws Implementation

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The regulations for the California Climate Corporate Data Accountability Act (SB253), which applies to entities with annual revenue in excess of $1 billion, have been delayed until the end of 2025. The California Air...more

Orrick, Herrington & Sutcliffe LLP

CFPB indicates its Section 1033 rule should be set aside in filing

On May 23, the U.S. District Court for the Eastern District of Kentucky received a status report from the defendants, the CFPB and Russell Vought, stating that the Bureau has determined the Section 1033 rule to be unlawful...more

Proskauer - Tax Talks

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules

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On May 20, 2025, California’s Franchise Tax Board (“FTB”) released changes to the proposed regulations (“Draft Regulations”) that would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Cozen O'Connor

Commerce Department Considers Applying Section 232 Duties on Steel and Aluminum to More Construction Materials

Cozen O'Connor on

Duties on steel and aluminum have already had a significant impact on the construction industry. Participants in the construction industry have a very short window in which to weigh in on changes that could increase the...more

Orrick, Herrington & Sutcliffe LLP

CFPB requests comment on its consumer complaint intake form

On May 22, the CFPB published a notice in the Federal Register requesting comments on the extension of the Consumer Complaint Intake System Company Portal Boarding Form. The Dodd-Frank Act requires the CFPB to facilitate the...more

Farella Braun + Martel LLP

EPA Announces Interim Rule Further Delaying TSCA Section 8(a)(7) PFAS Reporting by Nine Months

On May 12, 2025, EPA announced that it will publish an interim rule further delaying by nine months the one-time reporting required under TSCA section 8(a)(7) for entities manufacturing or importing PFAS at any time between...more

Benesch

Transportation Regulation Reforms - U.S. DOT Seeks Public Comment by May 5

Benesch on

The U.S. Department of Transportation is seeking public comment on opportunities to reform transportation regulations.  The comment period ends next week. This effort is part of President Trump’s “Ten for One” regulatory...more

DLA Piper

Maine DEP Extends CUU Designations by Two Years Under PFAS in Products Law

DLA Piper on

As discussed in our prior alert, Maine’s Department of Environmental Protection (DEP) published a proposed rule prescribing procedures and criteria for determining Currently Unavoidable Uses (CUU) of intentionally added per-...more

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

Greenberg Glusker LLP on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Schwabe, Williamson & Wyatt PC

OMB Seeks Public Input on Deregulation Under New Executive Order

The deadline to submit comments in response to the OMB’s solicitation is May 12, 2025. On April 11 the Office of Management and Budget published a request that interested parties “identify rules to be rescinded and provide...more

Snell & Wilmer

The (Almost) End of the Corporate Transparency Act

Snell & Wilmer on

In a whirlwind attempt to follow the roller coaster actions in the courts, the U.S. Congress, and FinCEN’s administrative efforts, Snell & Wilmer has worked to keep clients updated with the drama-filled developments of the...more

Stinson LLP

The End of Section 1071 as We Know It: CFPB to Reopen Rulemaking

Stinson LLP on

In a recent filing in the U.S. District Court for the Southern District of Florida, the Consumer Financial Protection Bureau (CFPB) disclosed that its new leadership has directed staff to initiate a fresh rulemaking process...more

Fox Rothschild LLP

Maine’s Draft Proposed Rule on PFAS “Currently Unavoidable Use” Determinations

Fox Rothschild LLP on

Maine recently published proposed rules (PDF link) aimed at implementation of its existing statute (which we’ve discussed here, here and here) limiting the sale and distribution within the state of products containing...more

Brooks Pierce

Corporate Transparency Act: FinCEN and the Treasury Announce Nonenforcement for Domestic Reporting Companies

Brooks Pierce on

Following announcements from the Financial Crimes Enforcement Network (“FinCEN”) on February 27, 2025, and the United States Department of the Treasury (the “Treasury”) on March 2, 2025, it would appear that beneficial...more

Warner Norcross + Judd

CTA Filing is Now Voluntary for US Entities and Citizens: Rule Changes Ahead

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The United States Treasury Department announced on March 2, 2025, that the Beneficial Ownership Information (BOI) reporting required by the Corporate Transparency Act (CTA) is now voluntary for U.S. entities and citizens....more

Katten Muchin Rosenman LLP

US Treasury Announces That the Corporate Transparency Act Will Not Be Enforced Against Domestic Companies, Their Beneficial Owners...

As noted in our previous Corporate Advisory, the Financial Crimes Enforcement Network (FinCEN) announced on February 27, 2025, that it will not take enforcement action against a Reporting Company that fails to file or update...more

Mintz - Energy & Sustainability Viewpoints

Sustainable Energy & Infrastructure CTA Updates — March 2025

FinCEN announced on February 27, 2025, that it will not impose fines or penalties for failures to file or update beneficial ownership information (BOI) reports in connection with the Corporate Transparency Act by the current...more

Perkins Coie

Corporate Transparency Act: Treasury Announces No Enforcement for Reporting Failures by U.S. Citizens and Domestic Reporting...

Perkins Coie on

Last week, we reported that the Financial Crimes Enforcement Network (FinCEN) reinstated the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements, with a new deadline for most...more

Foley Hoag LLP

FinCEN Pauses Enforcement of Corporate Transparency Act (Again!)

Foley Hoag LLP on

FinCEN has once again changed course on enforcement of the CTA. On February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against reporting companies based on a...more

Morgan Lewis

FinCEN Will Not Enforce Extended Corporate Transparency Act Filing Deadlines

Morgan Lewis on

Corporate Transparency Act (CTA) reporting requirements were recently reinstated, and the Financial Crimes Enforcement Network (FinCEN) established a new filing deadline of March 21, 2025. However, on February 27, 2025,...more

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