News & Analysis as of

Rulemaking Process Reporting Requirements

McDermott Will & Emery

IRS Roundup April 1 – April 17, 2025

The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax...more

Fenwick & West LLP

CARB to Hold Virtual Public Workshop Regarding California’s Corporate Climate Disclosure Rules

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The California Air Resources Board (CARB) has announced that it will hold a virtual public workshop to “support the development of California’s Corporate Greenhouse Gas Reporting Program,” as reflected in The Climate...more

Proskauer - Regulatory & Compliance

CSRD’s ESRS Draft Work Plan Faces Rejection At Latest EFRAG Meeting

On 15 April 2025, the sustainability reporting board (“SRB”) of the European Financial Reporting Advisory Group (“EFRAG”) failed to agree to an internal timeline for delivering advice to the European Commission on the...more

Paul Hastings LLP

New Mexico Passes Comprehensive Ban on PFAS in Products

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On April 8, 2025, New Mexico became the third state to sign into law a comprehensive ban on the use of intentionally added per- and polyfluoroalkyl substances (PFAS) in consumer and commercial products: the “Per- and...more

Greenberg Glusker LLP

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

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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

Snell & Wilmer

The (Almost) End of the Corporate Transparency Act

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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

Epstein Becker & Green

CTA Interim Final Rule Eliminates Requirements for U.S. Companies and U.S. Individuals to File Beneficial Ownership Reports

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN), in an action that was promised earlier in March, issued an interim final rule (the “Interim Rule”) that removes all requirements for U.S. companies and...more

Sheppard Mullin Richter & Hampton LLP

CFPB Seeks to Reopen Small Business Lending Rule Under Section 1071

On April 3, the CFPB informed a Florida federal district court that it plans to initiate new rulemaking to revise its small business lending data collection rule under Section 1071 of the Dodd-Frank Act. The Bureau agreed to...more

Ballard Spahr LLP

CFPB to Reopen Rulemaking on the Section 1071 Small Business Loan Data Collection and Reporting Rule

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As we have reported previously, including here, here, and here, the CFPB’s section 1071 small business loan data collection and reporting rule is facing court challenges.  The U.S. Court of Appeals for the Fifth Circuit has...more

Vedder Price

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

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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

Allen Matkins

SEC Abandons Defense Of Brobdingnagian Climate Change Disclosure Rule

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Three years ago, the Securities and Exchange Commission issued a nearly 500 page rule proposal that would require registrants to provide certain climate-related information in their registration statements and annual...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

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On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Brooks Pierce

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

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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

Davis Wright Tremaine LLP

Writing on a New SLATE – DWT's FINRA Expertise

The SEC's Rule 10c-1a now mandates the reporting of securities loans, marking a significant regulatory shift. Potential challenges in implementing SLATE, including the need for possible adjustments to data dissemination...more

Winstead PC

Corporate Transparency Act: Enforcement Suspended and New Rules to Come

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FinCEN and the Department of the Treasury both provided updates this week regarding the Corporate Transparency Act....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

Downs Rachlin Martin PLLC

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

The fate of the Corporate Transparency Act (CTA) has been anything but certain since the beneficial ownership information (BOI) reporting rule took effect in January 2024. While several legal challenges to the CTA make their...more

Fenwick & West LLP

The Corporate Transparency Act: Treasury Department Suspends Enforcement, Reporting Obligations

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In a press release issued on March 2, 2025, the Treasury Department, which oversees the Financial Crimes and Enforcement Network (FinCEN), announced that it will not enforce any penalties or fines associated with the existing...more

Chambliss, Bahner & Stophel, P.C.

Treasury Department Will Not Enforce Corporate Transparency Act Against U.S. Businesses

After months of uncertainty, legal challenges, and changing deadlines under the Corporate Transparency Act (CTA), the Treasury Department issued a press release on March 2, 2025, stating that it would not enforce any...more

BCLP

Treasury Suspends CTA Enforcement Against U.S. Citizens and Companies; Federal District Court Declares CTA Unconstitutional

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The Corporate Transparency Act (the “CTA”) remains in full force and effect, although FinCEN recently announced that it will not take any enforcement actions against reporting companies who fail either to file or to update...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

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

Wilson Sonsini Goodrich & Rosati

SEC Staff Expands Accommodations for Nonpublic Review of Draft Registration Statements

On March 3, 2025, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance (Division) announced an expansion of the nonpublic review process for draft registration statements. This expansion aims to...more

Hogan Lovells

Treasury announces there will be no penalties or fines for failure to file CTA beneficial ownership reports and proposes to narrow...

Hogan Lovells on

Key takeaways FinCEN and Treasury announce that there will be no enforcement for failure to file beneficial ownership information reports with FinCEN by the March 21 deadline. Treasury announced intention to narrow the scope...more

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