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DLA Piper

FTC’s “Click-to-Cancel” Rule Voided

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A unanimous three-judge panel of the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) final rule of amendments to the Negative Option Rule days before the rule’s scheduled July 14, 2025 effective date. The...more

Gardner Law

LDT Rule Vacated: FDA Backs Down, but Uncertainty Remains

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In December 2024, we published an alert highlighting the FDA’s final rule on Laboratory Developed Tests (LDTs) and the compliance countdown to May 2025. The rule, issued in May 2024, sought to phase out the agency’s...more

Ropes & Gray LLP

U.S. District Court Ruling Vacates HIPAA Final Rule that Strengthened Privacy Protections for Reproductive Health Information

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On June 18, 2025, the United States District Court for the Northern District of Texas Amarillo Division issued an opinion, Purl v. Department of Health and Human Services, declaring the U.S. Department of Health and Human...more

Paul Hastings LLP

UK Equity Capital Markets Insights — July 2025

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As noted in the April edition of this newsletter, the FCA consulted in February 2024 and November 2024 on proposed measures to update and streamline its enforcement guide and to increase transparency in how it goes about...more

Husch Blackwell LLP

MHPAEA July 2025 Update: What Employers and Plans Need to Know about Federal Non-Enforcement

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The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) was enacted to ensure that group health plans and health insurance issuers offering mental health and substance use disorder (MH/SUD) benefits do not impose...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 63: DOJ Issues Final Rule on International Data Transfers

Orrick Partners Matthew Coleman and Jeanine McGuinness join RegFi co-hosts Jerry Buckley and Sherry Safchuk to explore the implications of the Justice Department’s recent issuance of a final rule prohibiting and restricting...more

Quarles & Brady LLP

HIPAA Reproductive Health Rule Vacated Nationally

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A federal judge in Texas has vacated almost all of the 2024 HIPAA Rule to Support Reproductive Health Care Privacy that created special protections for reproductive health care information, finding that the U.S. Department of...more

Bass, Berry & Sims PLC

DOL Announces Enforcement Position on Independent Contractor Rule

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On May 1, the U.S. Department of Labor (DOL) issued a Field Assistance Bulletin announcing that the Wage and Hour Division (WHD) will no longer enforce the 2024 independent contractor Final Rule previously established by the...more

Snell & Wilmer

Limited Mental Health Parity Relief for Plan Sponsors

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On January 17, 2025, the ERISA Industry Committee (“ERIC”) filed suit in the U.S. Court of Appeals for the D.C. Circuit asking the court to hold various key provisions under the 2024 Mental Health Parity Addiction Equity Act...more

Perkins Coie

FCC Plugs National Security Gaps by Targeting “Bad Labs”

Perkins Coie on

Key Takeaways - - Per a recent FCC final rule, telecommunication certification bodies owned or controlled by “prohibited entities,” including Chinese government and military affiliates, are prohibited from testing and...more

Davis Wright Tremaine LLP

What Relief Does the Mental Health Parity and Addiction Equity Act Nonenforcement Policy Actually Provide to Employers?

Employers navigating the complexities of the Mental Health Parity and Addiction Equity Act ("MHPAEA") may find themselves questioning the true impact of the federal government's recently issued nonenforcement policy. This...more

Groom Law Group, Chartered

Departments Pause Enforcement of MHPAEA Final Rule and Reconsider MHPAEA Enforcement Program

In a widely anticipated and welcome move, the Departments of Health and Human Services (“HHS”), the Treasury, and Labor (“DOL”) (collectively, the “Departments”), sought an abeyance of a lawsuit challenging the Mental Health...more

Littler

The Parity Paradox: MHPAEA Compliance for Employers and Insurers During the 2024 Enforcement Pause

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The U.S. Departments of Labor, Health and Human Services, and Treasury have announced that they will pause enforcement of the 2024 Mental Health Parity and Addiction Equity Act (MHPAEA) Final Rule (the “2024 Final Rule”) for...more

Bond Schoeneck & King PLLC

Administration Grants Welcome Reprieve From Certain NQTL Requirements

Administration Grants Welcome Reprieve From Certain NQTL Requirements - Earlier this month, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) announced that for the foreseeable future...more

Orrick, Herrington & Sutcliffe LLP

CFPB to rescind state requirement to notify Bureau on CFPA enforcement

On May 21, the CFPB published a notice in the Federal Register withdrawing its procedures that required state officials to notify the Bureau when taking action to enforce the CFPA. The direct final rule, effective July 21,...more

Warner Norcross + Judd

Delayed Enforcement of Mental Health Parity NQTL Comparative Analysis Final Regulations

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Under the Mental Health Parity and Addiction Equity Act (MHPAEA), as amended by the Consolidated Appropriations Act (CAA), 2021, group health plans and health insurance issuers must conduct comparative analyses to show that...more

Venable LLP

Government Issues Nonenforcement Statement on Mental Health Parity Rules

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The government recently stated that it will delay enforcement of the 2024 final rules on the Mental Health Parity and Addiction Equity Act (MHPAEA). (Our previous alert regarding the 2024 final rules can be found here.) This...more

Foley & Lardner LLP

Mental Health Parity Alert - Non-Enforcement of Final Rules

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The Mental Health Parity and Addiction Equity Act (MHPAEA), and its implementing regulations and guidance, prohibits health insurance policies and group health plans that cover mental health and substance use disorder...more

Quarles & Brady LLP

Departments Will Not Enforce 2024 Final Rule under MHPAEA

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The Trump Administration has just announced that it will pause enforcement of the September 2024 final rule (“Final Rule”) under the Mental Health Parity and Addiction Equity Act (“MHPAEA”)....more

Snell & Wilmer

FTC Click-to-Cancel Rule Enforcement Delayed 60 Days to Enable Business Compliance

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Enforcement of the Federal Trade Commission (FTC) Click-to-Cancel Rule (Rule) has now been deferred to July 14, 2025. The FTC noted that enforcement of the Rule did not adequately consider the compliance burdens...more

Morgan Lewis - ML Benefits

Mental Health Parity Non-Enforcement Statement Released

The US Departments of Labor, Health and Human Services, and the Treasury (the Departments) announced their non-enforcement policy on May 15, 2025, indicating they will not enforce any new requirements imposed by the...more

Fox Rothschild LLP

EPA Keeps MCL for PFOA and PFOS, Extends Compliance Deadline, and Intends to Rescind MCL for PFHxS, PFNA, GenX, and PFBS

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EPA announced on May 14, 2025 that it will maintain the Maximum Contaminant Level (“MCL”), also known as the national primary drinking water standard, for two PFAS, perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic...more

Loeb & Loeb LLP

60 More Days for Click to Cancel

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Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...more

Cooley LLP

FTC Delays Enforcement of Amended Negative Option Rule

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On May 9, the Federal Trade Commission (FTC) voted unanimously to delay enforcement of most portions of its amended Negative Option Rule (rule) by 60 days, shifting the compliance deadline for these portions from May 14 to...more

Orrick, Herrington & Sutcliffe LLP

UPDATE: DOJ Issues Bulk Sensitive Data Rule Guidance, Requirements Go into Effect: What Companies Need to Know

On April 11, 2025, the Department of Justice’s (DOJ) National Security Division (NSD) released an Implementation and Enforcement Policy, a Compliance Guide, and a list of over 100 Frequently Asked Questions (FAQs) to help...more

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