News & Analysis as of

Rulemaking Process Settlement

Mayer Brown

A Post-CARS Rule Brake? Not So Fast. Buckle Up for New Regulatory Activity in the Motor Vehicle Space

Mayer Brown on

The Fifth Circuit vacated the Federal Trade Commission’s (“FTC”) Combating Auto Retail Scams Trade Regulation Rule (“CARS Rule”) on January 27, 2025, determining that the FTC failed to follow its own procedural requirements...more

BakerHostetler

More Scrutiny of California Data Brokers

BakerHostetler on

As with many other areas of privacy law, it is not surprising that California continues to lead the nation in regulating data brokers – from promulgating new regulations to issuing a cluster of recent settlements. ...more

Oberheiden P.C.

Targeting MLMs and Other “Money-Making Opportunity Sellers” Remains an FTC Priority in 2025

Oberheiden P.C. on

Targeting multi-level marketers (MLMs) and other “money-making opportunity sellers” has been among the U.S. Federal Trade Commission’s (FTC) top priorities in recent years. The FTC has pursued several enforcement actions...more

Akin Gump Strauss Hauer & Feld LLP

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

DarrowEverett LLP

Actions vs. J.P. Morgan, Monolith Serve as SEC Compliance Check Reminders

DarrowEverett LLP on

The Securities and Exchange Commission (SEC) recently settled charges against J.P. Morgan Securities LLC (JPMS) for impeding hundreds of advisory clients and brokerage customers from reporting potential securities law...more

Proskauer - The Capital Commitment

2023 SEC Enforcement Results – Takeaways for Fund Managers

On November 14, 2023, the SEC’s Division of Enforcement announced its Enforcement Results for Fiscal Year 2023. Below are some key takeaways for fund managers: The Commission brought 760 total enforcement actions in FY...more

ArentFox Schiff

February Privacy Report: FTC Expands Its Use of “Unfairness” Authority in GoodRx Matter

ArentFox Schiff on

GoodRx Faces Million Dollar Proposed Penalty from FTC in First Enforcement Action Under the Health Breach Notification Rule - Settlement reveals views on application of unfairness authority to sharing of sensitive...more

Pillsbury Winthrop Shaw Pittman LLP

SEC’s Heightened Scrutiny of Rule 10b5-1 Plans and Final Rulemaking Focus Is on Insiders Rather than Issuers

The SEC seeks to regulate trading through internal compliance processes. The SEC settled insider trading charges in relation to misuse of a Rule 10b5-1 plan established in the name of a British Virgin Islands entity owned...more

Carlton Fields

SEC Now May Consider a Simultaneous Settlement Offer and Waiver Request

Carlton Fields on

Certain “bad actors” who settle with the SEC may be subject to automatic disqualifications or collateral consequences under federal securities laws and regulations. The Commission, however, may grant a settling party’s...more

Ballard Spahr LLP

CFPB settles lawsuit against online payday lenders

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The CFPB announced that it has settled a lawsuit that it filed in 2014 in a Missouri federal district court alleging that the defendants engaged in unlawful online payday lending schemes.  ...more

Broker-Dealer Compliance + Regulation

FINRA and T+2: The Rule Roll-Out Begins

As the U.S. financial markets commence their move towards a T+2 settlement period, FINRA has introduced a proposed set of rule changes designed to support this change. The current timetable contemplates that the changes...more

Stoel Rives LLP

California Attorney General Targets Prop. 65 Plaintiffs’ Settlement Terms

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The California Office of the Attorney General is seeking to limit certain payment provisions common in Prop. 65 plaintiffs’ settlements with defendants. The proposed rulemaking, published September 25, 2015, would limit the...more

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