News & Analysis as of

Disclosure Requirements Rulemaking Process

Wilson Sonsini Goodrich & Rosati

SEC Requests Eighth Circuit Decide Climate Rules Litigation

On July 23, 2025, the U.S. Securities and Exchange Commission submitted a status report to the U.S. Court of Appeals for the Eighth Circuit regarding the final climate-related disclosure rules. According to the status report,...more

Mintz - Securities & Capital Markets...

SEC Roundtable on Executive Compensation Disclosure

The Securities and Exchange Commission held a roundtable at the SEC’s headquarters in Washington, DC on June 26, 2025 to discuss possible changes to the Commission’s requirements for executive compensation disclosure...more

Mayer Brown

Click-to-Cancelled! Eighth Circuit Vacates Federal Trade Commission’s Revised Negative Option Rule

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INTRODUCTION - On July 8, 2025, the Eighth Circuit issued its decision in Custom Communications, Inc. v. Federal Trade Commission, vacating on procedural grounds the FTC’s planned “Click-to-Cancel” rule (the “Rule”), which...more

Proskauer - Advertising Law

Canceled Before It Clicked: Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

Just days before it was set to take effect, the U.S. Court of Appeals for the Eighth Circuit struck down the Federal Trade Commission’s (FTC) much anticipated “Click-to-Cancel Rule” (the “Rule”), delivering regulatory...more

Benesch

Eighth Circuit Cancels FTC’s “Click-to-Cancel” Rule

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On July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Negative Option Rule, also referred to as the “Click-to-Cancel” rule (the “Rule”), determining that the FTC...more

Arnall Golden Gregory LLP

Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

On July 8, 2025, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click-to-Cancel Rule, resolving the challenges to the rule filed on the heels of its adoption in...more

Miller Canfield

Eighth Circuit Slams the Brakes on FTC’s Click-to-Cancel Rule

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In a dramatic turn of events, the United States Court of Appeals for the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) Click-to-Cancel Rule, which was set to take effect on July 14, 2025. ...more

Ropes & Gray LLP

FTC’s “Click-to-Cancel” Rule Struck Down by Eighth Circuit

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On Tuesday July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) “Negative Option” Rule, also called the “Click-to-Cancel” Rule, which expanded regulations on...more

Alston & Bird

FTC’s Click-to-Cancel Rule Vacated by Appeals Court

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Due to go into effect on July 14, the Negative Option Rule has been struck down by the Eighth Circuit. Our Consumer Protection/FTC Group examines the Federal Trade Commission’s options going forward....more

Dickinson Wright

Rule Interrupted: “Click-to-Cancel” is “Click-to-Gone”

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The Federal Trade Commission’s (FTC) negative option rule, better known as the “Click-to-Cancel” rule, which was set to go into effect July 14, 2025, has been vacated in its entirely by the Eighth Circuit in Custom...more

Lerman Senter PLLC

"Click to Cancel" Rule Vacated Ahead of July 14th Deadline

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Just days before the “Click to Cancel” negative option rule was to go into effect, the Eight Circuit Court of Appeals vacated the rule in its entirety. As explained in our previous alert, the rule, which would have gone into...more

Mayer Brown

Important Texas Regulatory Updates for Data Centers

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​​​​​​​On May 27, 2025, the Texas Legislature passed SB-6, which introduces significant changes to the planning, interconnection, operation, and cost allocation of certain large electrical loads within the Electric...more

DLA Piper

Observations from the SEC Roundtable on Executive Compensation

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The Securities and Exchange Commission (SEC) held its Roundtable on the executive compensation disclosure requirements at its headquarters in Washington, DC on June 26, 2025. Chairman Paul S. Atkins set the tone in his...more

Kelley Drye & Warren LLP

Eighth Circuit Vacates FTC’s Negative Option Rule

On the metaphorical eve of the July 14 effective date for the FTC’s Negative Option Rule, the Eighth Circuit released an opinion Tuesday vacating the Rule in its entirety. The economy-wide notice, consent, cancellation, and...more

Vinson & Elkins LLP

Insights from the SEC Roundtable on Executive Compensation Disclosure Requirements

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On June 26, 2025, the U.S. Securities and Exchange Commission (“SEC”) hosted a roundtable on executive compensation disclosure requirements. As noted in prior Insights, the SEC convened the roundtable to evaluate the...more

Troutman Pepper Locke

SEC Conducts Roundtable on Executive Compensation Disclosure Practices

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As previewed in our previous blog post, the Securities and Exchange Commission (SEC) hosted a roundtable on executive compensation disclosure on June 26, with panelists considering whether and to what extent the current...more

Cooley LLP

Corp Fin Revises Two (And Withdraws One) Legal Proceeding Disclosure CDIs

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A few weeks ago, Corp Fin revised two – and withdrew one – of the Legal Proceedings CDIs under Item 103 of Regulation S-K. These CDI changes are catching up to the reorg of Item 103 that the SEC made five years ago when the...more

Frost Brown Todd

California’s Climate Disclosure Rulemaking Enters a New Phase

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California’s requirements for climate-related corporate disclosures are evolving as the California Air Resources Board (CARB) continues to implement Senate Bill (SB) 253 and SB 261. Although these statutes were enacted in...more

Carlton Fields

Takeaways from the SEC Roundtable on Executive Compensation Disclosure Rules

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On June 26, the Securities and Exchange Commission hosted a roundtable discussion about potential changes to existing executive compensation disclosure requirements. In the lively discussion, panelists representing issuers,...more

Ballard Spahr LLP

CFPB will not issue revised BNPL rule

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Having previously announced that it was withdrawing its Buy Now, Pay Later rule, the CFPB recently said that it does not intend to issue a revised rule....more

Vinson & Elkins LLP

SEC Roundtable on Executive Compensation Disclosure Requirements: June 26, 2025

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As we previously noted last month, the SEC is hosting a roundtable on the executive compensation disclosure requirements on June 26, 2025. In advance of the roundtable, the SEC has finalized and released a detailed agenda and...more

Stikeman Elliott LLP

SEC Considers Amendments to “Foreign Private Issuer” Definition

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The U.S. Securities and Exchange Commission (“SEC”) recently published a concept release (the “Concept Release”) in which it solicits comments on potential revisions to the “foreign private issuer” (“FPI”) definition. The SEC...more

Jones Day

SEC Withdraws Proposed ESG Disclosure and Shareholder Submission Rules

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In a significant but not unsurprising policy shift, the U.S. Securities and Exchange Commission (SEC) has announced the withdrawal of proposed rules aimed at enhancing ESG disclosures and modifying shareholder proposal...more

Paul Hastings LLP

SEC Withdraws 14 Pending Rule Proposals

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On June 12, the Securities and Exchange Commission (SEC) formally withdrew 14 proposed rules for investment advisers, broker-dealers and public companies, many of which had been pending for several years. Should the SEC...more

Ropes & Gray LLP

SEC Clears Unfinished Rulemakings from Regulatory Agenda

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On June 12, 2025, the SEC issued a notice (the “Notice”) formally withdrawing certain proposed rulemakings issued in 2022 and 2023. Of particular interest to the investment management industry, the Notice withdraws the...more

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