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Rulemaking Process Reporting Requirements Proposed Rules

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

Ballard Spahr LLP on

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

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

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

Tonkon Torp LLP

The Corporate Transparency Act – Penalties Suspended

Tonkon Torp LLP on

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

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

Ballard Spahr LLP

Department of the Treasury Suspends Enforcement of the Corporate Transparency Act and Plans to Revise Rule to Limit Scope

Ballard Spahr LLP on

Does it matter if a law is valid if the Government refuses to enforce it? For months, we have watched (and blogged on) courts grappling with the constitutionality and enforceability of the Corporate Transparency Act (“CTA”)....more

Neal, Gerber & Eisenberg LLP

Treasury Limits CTA Enforcement to Foreign Companies

On March 2, 2025, the Treasury Department expanded the scope of FinCEN’s February 27, 2025 statement that it will not enforce any penalties or fines under the Corporate Transparency Act with respect to existing regulatory...more

Wiley Rein LLP

Treasury Says It Won’t Enforce Corporate Transparency Act Against U.S. Companies or Citizens

Wiley Rein LLP on

Treasury / FinCEN - Interim Final Rule and Proposed Rulemaking - On March 2, 2025, the U.S. Department of the Treasury issued a press release stating that it will not enforce any penalties or fines against U.S. citizens or...more

Foley & Lardner LLP

Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting...

Foley & Lardner LLP on

The Treasury Department announced plans to significantly narrow beneficial ownership information (BOI) reporting obligations under the Corporate Transparency Act (CTA)....more

McGuireWoods LLP

Treasury Department Declares Intent to Limit CTA to Foreign Reporting Companies

McGuireWoods LLP on

After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline under the Corporate...more

Snell & Wilmer

The Corporate Transparency Act Update: A Reprieve for American Businesses?

Snell & Wilmer on

In another twist as to the future of the Corporate Transparency Act’s (CTA) implementation and judicial intervention, on February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will not be...more

Dinsmore & Shohl LLP

FinCEN Will Not Enforce CTA Penalties and Intends to Further Extend Filing Deadlines

Dinsmore & Shohl LLP on

On February 27, 2025, FinCEN issued a news release stating that it will not impose fines or penalties for failure to file Beneficial Ownership Information (BOI) reports by the current deadlines. This follows FinCEN’s February...more

Paul Hastings LLP

DOJ Announces Significant Proposed Changes to Amend and Clarify FARA

Paul Hastings LLP on

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

Fenwick & West LLP

Nasdaq Proposes Eliminating Board Diversity Disclosure Rule

Fenwick & West LLP on

Last week, Nasdaq filed a proposed rules change with the Securities and Exchange Commission to remove the board diversity rule from Nasdaq's Listing Rules....more

Morrison & Foerster LLP - Government...

Proposed Greenhouse Gas FAR Clause Withdrawn as Inauguration Approaches

The Biden Administration withdrew a proposed climate change-inspired amendment to the Federal Acquisition Regulation (FAR) one week before former President Donald Trump’s return to the White House. According to a notice...more

Wiley Rein LLP

CBP Issues Proposed Changes to De Minimis Import Process

Wiley Rein LLP on

On January 14, 2025, U.S. Customs and Border Protection (CBP) issued a proposal to alter its regulations regarding de minimis imports. Section 321(a)(2) of the Tariff Act of 1930 currently authorizes duty exemptions, as well...more

Schwabe, Williamson & Wyatt PC

SBA Proposes Faster Payments and Simplified Reporting

On December 19, the Small Business Administration published proposed amendments to 13 CFR § 125.3 that would affect small business subcontracting. Their goal is to accelerate payments to small business subcontractors and...more

Davis Wright Tremaine LLP

5th Circuit Again Adopts Restrictive View of Exchange Act Purposes and SEC Regulatory Power

On December 11, 2024, the 5th Circuit issued another important opinion (for the third time this year) requiring that an administrative agency's rules fit squarely within the statutory scheme that empowers the agency to act....more

Troutman Pepper Locke

Highlights from the CFPB’s Spring 2024 Semi-Annual Regulatory Agenda

Troutman Pepper Locke on

The Consumer Financial Protection Bureau (CFPB or Bureau) recently released its semi-annual regulatory agenda, outlining its planned rulemaking initiatives. The CFPB releases regulatory agendas twice a year in voluntary...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Perkins Coie

CISA Seeks Input on New Cybersecurity Reporting Requirements

Perkins Coie on

President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The background and contours of CIRCIA are discussed in a previous update. CIRCIA authorizes and...more

Sheppard Mullin Richter & Hampton LLP

Cybersecurity Act Signed Into Law Creates New Reporting Obligations

President Biden recently signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 as a part of a larger omnibus appropriations bill.  The new law sets out mandatory reporting requirements for...more

Goodwin

Draft Implementing Rules of China’s Human Genetic Resources Regulations as Applied to Foreign Persons

Goodwin on

The Administrative Regulations of the People’s Republic of China on Human Genetic Resources (the “Regulations”), promulgated by China’s State Council, have been in effect for almost three years. As the administrative...more

Goodwin

Stress Test Scenarios Released for 2022

Goodwin on

In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

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