News & Analysis as of

Comment Period Compliance

A&O Shearman

EBA consults on draft RTS and guidelines for third country branches under CRD IV

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The European Banking Authority (EBA) has published three consultation papers under Directive 2013/36 (CRD IV), as amended by Directive 2024/169 (CRD VI), relating to the regulatory requirements for third country branches...more

Wiley Rein LLP

Commerce Seeks Comments on UAS Imports in New Section 232 Investigation

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On July 16, 2025, the U.S. Department of Commerce published a Federal Register notice soliciting public comments on an investigation into the national security impacts of imported unmanned aircraft systems (UAS or drones) and...more

Wiley Rein LLP

New Jersey Proposes New Privacy Rules That Would Impact Compliance

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On June 2, the New Jersey Division of Consumer Affairs (Division) published proposed regulations to implement the New Jersey Data Privacy Act (NJDPA). Of note, these rules were proposed months after the NJDPA went into effect...more

Mintz - Technology, Communications & Media...

Telephone and Texting Compliance News: Regulatory Update — FCC Seeks Comment on Petitions Focused on Quiet Hour and Utility...

Amid a surge in Telephone Consumer and Protection Act (TCPA) lawsuits, two groups filed Petitions for Declaratory Ruling before the Federal Communications Commission (FCC) this month, seeking clarity on several current TCPA...more

Cadwalader, Wickersham & Taft LLP

Comments Would Limit Circular 230 Proposed Regulations

On December 26, 2024, the IRS published proposed regulations on Circular 230, which governs the conduct of practitioners who practice before the IRS. The New York State Bar Association Tax Section (NYSBA) has submitted...more

Akin Gump Strauss Hauer & Feld LLP

HHS, FDA Announce Multiple Initiatives on Food Safety, Quality and Compliance Fronts

In the past week, the U.S. Food and Drug Administration (FDA), in collaboration with the Department of Health and Human Services (HHS) announced three new initiatives related to food safety and food supply chain transparency....more

Perkins Coie

Your Chance To “Delete” FCC Rules

Perkins Coie on

As long anticipated, Federal Communications Commission (FCC) Chairman Brendan Carr has launched a new proceeding to eliminate policies and rules that may no longer be necessary or that impose undue regulatory burdens. The...more

Sheppard Mullin Richter & Hampton LLP

FedRAMP Releases New Draft Authorization Boundary Guidance

Over the last few years, the Federal Risk and Authorization Management Program (“FedRAMP”) Program Management Office (“PMO”) has released two draft guidance documents related to defining the applicable boundary for security...more

Orrick, Herrington & Sutcliffe LLP

CFPB Proposal to Broaden EFTA/Reg E Scope has Implications for Crypto, Gaming and Credit Cards

On Friday, January 10, the Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule that could significantly broaden the scope of the Electronic Fund Transfer Act (EFTA) to encompass a wide range of digital...more

Fenwick & West LLP

FDA Issues Draft Guidances on AI in Medical Devices, Drug Development: What Manufacturers and Sponsors Need to Know

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The Food and Drug Administration (FDA) has recently released two draft guidance documents (Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations and...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

BakerHostetler

The DoD’s CMMC Rule Is Out: What Comes Next?

BakerHostetler on

On October 15, 2024, the Department of Defense (DoD) published the final rule for the Cybersecurity Maturity Model Certification (CMMC) Program that not only finalizes the long-anticipated CMMC Rule but also foreshadows what...more

Venable LLP

Key Insights: DOJ's Proposed Rule to Protect Bulk Sensitive Personal Data—What Companies Need to Know

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Earlier this year, the Biden administration issued Executive Order (EO) 14117, which instructed the Department of Justice (DOJ) to create a framework that would prohibit certain data transactions. ...more

WilmerHale

DOJ Issues NPRM Regarding Sensitive Data Transfers

WilmerHale on

With the publication of a recent Notice of Proposed Rulemaking (NPRM), the Department of Justice National Security Division will soon become an important new regulator of transactions involving the transfer of sensitive U.S....more

Holland & Knight LLP

BIS Proposes Rule to Secure Connected Vehicle Supply Chains from Foreign Adversary Threats: Rule Will Create New Compliance...

Holland & Knight LLP on

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued a Notice of Proposed Rulemaking (Proposed Rule) on Sept. 26, 2024, to address certain undue or unacceptable risks identified in Executive Order...more

BCLP

Synapse Failure Spurs FDIC To Specify Record Keeping for Bank Sponsored Fintechs

BCLP on

The Federal Deposit Insurance Corporation (“FDIC”) proposed in its Notice of Proposed Rulemaking (“NPR”) that insured IDIs keep records of individual accounts that are typically held in pooled custodial accounts that support...more

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

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The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more

Venable LLP

Federal Banking Agencies Highlight Bank-Fintech Partnership Risks and Invite Comment

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On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more

BCLP

SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

BCLP on

On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

Venable LLP

CFIUS Proposes Increased Penalties for Noncompliance and Updated Mitigation and Enforcement Rules

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As the lead agency for the Committee on Foreign Investment in the United States (CFIUS or the Committee), the U.S. Department of the Treasury released new proposed rules on April 11, 2024 intended to enhance the enforcement...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

BakerHostetler on

The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

Barnea Jaffa Lande & Co.

MiCA and Reverse Solicitation

Non-EU or non-MiCA compliant entities that want to offer or provide crypto-asset services to clients in the EU must be aware of the newly drafted guidelines from the European Securities and Markets Authority (ESMA). The...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

White House Publishes Revisions to Federal Agency Race and Ethnicity Reporting Categories

On March 28, 2024, the White House unveiled revisions to the federal statistical standards for race and ethnicity data collection for federal agencies, adding a new category and requiring a combined race and ethnicity...more

Health Care Compliance Association (HCCA)

In This Month’s E-News: April 2024

Arguing that the National Science Foundation (NSF) was “intricately involved” when it made a $1.125 million fixed amount subaward, Oklahoma University (OU) objected to a recent finding by auditors for the NSF Office of...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

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On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

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