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Transparency Disclosure Requirements Proposed Rules

MoFo Life Sciences

HHS Secretary to FDA: Consider Elimination of GRAS Self-affirmation Pathway

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On March 10, the U.S. Department of Health and Human Services (HHS) issued a press release emphasizing “radical transparency to make sure all Americans know what is in their food” and announcing that HHS Secretary Robert F....more

A&O Shearman

The end of the road for (most of) the FCA's transparency proposals

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Just over a year ago, the UK Financial Conduct Authority (FCA) found itself at the centre of strong industry and political feedback when it first published its controversial proposals to ‘name and shame’ firms that it had...more

Ruder Ware

Hello, Goodbye: CTA Enforcement Suspended

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The U.S. Department of the Treasury suspended enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic reporting companies. On Sunday night, the Treasury announced that U.S. citizens and domestic...more

Hogan Lovells

UK FCA “naming and shaming” proposals: the House of Lords steps in.

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The House of Lords Financial Services Regulation Committee (“FSRC”) has published a report on the Financial Conduct Authority’s (“FCA”) proposals to change its approach to announcing enforcement investigations, from...more

Benesch

When “No Comment” Isn’t an Option: FMCSA Publishes Proposed “Broker Transparency” Regulation

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The Federal Motor Carrier Safety Administration (“FMCSA”) issued a Notice of Proposed Rulemaking (“NPRM”) on November 20, 2024,titled Transparency in Property Broker Transactions (89 FR 91648). ...more

Sullivan & Worcester

Are the SEC’s Private Fund Advisers Rules Now Dead? No, but they are on Life Support

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The U.S. Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) has thrown a wrench into the gears of the U.S. Securities and Exchange Commission (the “SEC”) in its attempt to regulate those investment advisers that...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Pillsbury Winthrop Shaw Pittman LLP

AI and the “G” in ESG

As artificial intelligence (AI) expands into virtually every industry, companies should consider AI’s potential impacts on corporate governance and internal controls. Companies should integrate AI thoughtfully to ensure...more

Hinch Newman LLP

FTC Proposes Rule to Prohibit Hidden and Falsely Advertised Fees

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On October 11, 2023, the Federal Trade Commission announced a new proposed rule to prohibit “junk fees,” which the FTC states are hidden and bogus fees that can harm consumers and undercut honest businesses. FTC...more

Holland & Knight LLP

Summary and Early Analysis of New SEC Private Fund Rules

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The U.S. Securities and Exchange Commission (SEC) on Aug. 23, 2023, adopted the long-awaited private fund rules (Private Fund Rules) under the Investment Advisers Act of 1940 (Advisers Act) as part of SEC Release No. IA-6383...more

White & Case LLP

SEC Adopts Final Private Fund Adviser Rules

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New rules are expected to have substantial impact on funds industry - On August 23, 2023, the Securities and Exchange Commission ("SEC") approved significant new rules applicable to advisers of private funds (the "Private...more

DarrowEverett LLP

What SEC’s Transparency Rule Means for Investors, Advisers and Funds

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Earlier this summer, we wrote about both new and amended rules proposed by the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”) regarding private funds, their advisers,...more

DarrowEverett LLP

Proposed SEC Rules Aim at Putting Private Funds More in Public View

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Whether everyday Americans saving for retirement, college tuition, or their forever homes know it or not, there’s a chance that their money is tied, directly or indirectly, to private funds. Moreover, those Americans probably...more

ArentFox Schiff

Proposed Nursing Home Disclosure Requirements Target Private Equity Companies and REITs

ArentFox Schiff on

On February 15, 2023, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule which would require greater disclosures of the ownership and management of Medicare and Medicaid nursing homes. Specifically,...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Short Sale Disclosure Rules

On February 25, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it unanimously voted to approve proposed changes requiring certain institutional investment managers (managers) to report short...more

Patterson Belknap Webb & Tyler LLP

SEC Proposes New Rule Requiring Increased Disclosure of Short Sale Information

In 2010, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act, which required the SEC “to prescribe rules to make certain short sale data publicly available no less than monthly.”...more

Holland & Knight LLP

Something We Can All Agree On? SEC Unanimously Approves Proposed Short-Seller Disclosure Rules

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Section 929X of the Dodd-Frank Act requires the SEC to implement a regulatory framework around the public disclosure of short sale information. On Feb. 25, 2022, the SEC unanimously approved proposed rules aimed at satisfying...more

Holland & Knight LLP

SEC to Vote Next Week on Proposing New Hedge Fund Disclosure Requirements

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Enhanced disclosure requirements may be coming soon for hedge funds and private equity firms. U.S. Securities and Exchange (SEC) Commissioner Chair Gary Gensler said on Jan. 19, 2022, that the regulator will vote next week on...more

Mintz - Health Care Viewpoints

Health Plan Transparency Rule: Comment Period Ends This Week

In November 2019, the U.S. Department of Health and Human Services, along with the U.S. Department of Treasury and the U.S. Department of Labor, (collectively, the Departments) released a proposed rule requiring group health...more

King & Spalding

CMS Finalizes Rule to Require Hospitals to Disclose Negotiated Rates

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The Department of Health and Human Services (HHS), and the Trump Administration as a whole, has placed a particular focus on the promotion of price transparency as a tool to control the costs of healthcare. In June, the...more

Bass, Berry & Sims PLC

Trump Administration Proposes Transparency Rule for Group Health Plans and Insurers

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On November 15, 2019, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the Departments), unveiled a proposed rule (scheduled to be published on November...more

McDermott Will & Emery

Rethinking Transparency – Inpatient Prospective Payment System Final Rule Rescinds Proposed Survey Disclosure Rule

The 2018 IPPS/LTCH PPS proposed rule contained a provision that would have required AOs to make survey reports and acceptable plans of correction publicly available within approximately three months of issuance. The Final...more

Holland & Knight LLP

SEC Issues New Material Event Notices Under Proposed Rule 15c2-12 Amendments

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The U.S. Securities and Exchange Commission (SEC) on March 1, 2017, proposed adding two additional triggers – in new subparagraphs (15) and (16) – for the material events notice requirements under Rule 15c2-12 (the Proposed...more

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