News & Analysis as of

Interim Final Rules (IFR)

Pillsbury - PFAS Observer

EPA Issues Second Extension of PFAS Reporting Timeline Under TSCA Section 8(a)(7)

On May 12, 2025, EPA announced that it will again revise the reporting timeline for manufacturers of per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The data...more

Latham & Watkins LLP

OCC Bank Merger Rule Rescinded in Latest Regulatory Reversal

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The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications....more

Bradley Arant Boult Cummings LLP

CFPB Rescinding the 2021 COVID-19 Mortgage Servicing Final Rule

On May 15, 2025, the Consumer Financial Protection Bureau (CFPB) filed an interim final rule in the Federal Register that will rescind its prior 2021 COVID-19 mortgage servicing final rule. The interim final rule is set for...more

WilmerHale

US Export Controls on “AI Diffusion” Officially Paused, but New Guidance Elevates Risk for AI-Related Exports

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On May 13, 2025, the Department of Commerce formally signaled its intention to rescind the Biden Administration’s Framework for Artificial Intelligence Diffusion (AI Diffusion Rule) two days before the January 2025 Interim...more

BCLP

TSCA PFAS Reporting Delayed (Again)

BCLP on

The United States Environmental Protection Agency (“EPA”) has announced it will again be extending the data submission period for the Toxic Substances Control Act (“TSCA”) Section 8(a)(7) reporting requirement for per- and...more

Bergeson & Campbell, P.C.

EPA Postpones TSCA PFAS Reporting Period to April 2026

The U.S. Environmental Protection Agency announced on May 12, 2025, an interim final rule that would extend the dates of the reporting period for data submitted on the manufacture of perfluoroalkyl or polyfluoroalkyl...more

Pillsbury Winthrop Shaw Pittman LLP

The Ironic Impact of FinCEN’s New CTA Regulations on New York’s LLC Transparency Act

The NYS LLC Transparency Act (the “New York Act”) became law in January 2024 and takes effect on January 1, 2026. When in effect, it would require limited liability companies formed or qualified to do business in New York to...more

Guidepost Solutions LLC

Unlocking Opportunity: Navigating the New Data Center Validated End User Program

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a significant interim final rule (IFR) that has created both challenges and exciting opportunities for these operators. This IFR...more

King & Spalding

U.S. Department of Commerce Launches New Process for Certain Parties to Request Additional Derivative Products Become Subject to...

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On May 2, 2025, the U.S. Department of Commerce (“Commerce”) issued an interim final rule (“IFR”) that creates a new process for adding goods to the lists of derivative products subject to the 25 percent steel and aluminum...more

Saul Ewing LLP

Navigating the DHS Registration Requirement for Foreign Nationals

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On March 12, 2025, the U.S. Department of Homeland Security (“DHS”) issued an Interim Final Rule (“IFR”) implementing a new registration requirement (“Registration Requirement”) for certain foreign nationals to be filed with...more

Troutman Pepper Locke

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

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As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

Pillsbury Winthrop Shaw Pittman LLP

CTA Deadline Approaching for Foreign Reporting Companies

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

Bass, Berry & Sims PLC

FinCEN Interim Final Rule Signals End of Domestic Entities’ CTA Reporting Obligations

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After almost 18 months of uncertainty and confusion with respect to the implementation and enforcement of the Corporate Transparency Act (CTA), on Friday, March 21, the U.S. Department of Treasury’s Financial Crimes...more

Sheppard Mullin Richter & Hampton LLP

What Do Employers Need to Know About the New DHS Alien Registration Requirement?

As further implementation of the January 20, 2025 Executive Orders, DHS recently published an interim final rule regarding the requirement that certain non-citizens register with the U.S. Department of Homeland Security...more

Gibney Anthony & Flaherty, LLP

Update: New Regulation on Alien Registration Requirement Takes Effect on April 11 After Federal Judge Denies Request for...

The U.S. Department of Homeland Security (DHS) Interim Final Rule (IFR) requiring non-citizens who remain in the U.S. for 30 days or more — and were not previously registered — to register and carry proof of their...more

Tonkon Torp LLP

Registration Requirement for Certain Noncitizens in the U.S. for 30 Days or Longer, Effective April 11, 2025

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The Trump administration continues extreme vetting and full enforcement of existing (even if dormant) immigration laws, including the requirement that noncitizens be registered with the government. The government refers to...more

Ruder Ware

Noncitizens Should Review their Compliance with Registration and Change of Address Notification Requirements

Ruder Ware on

On March 12th, the Department of Homeland Security published an Interim Final Rule (“IFR”) partially implementing section 7 of Executive Order 14159, Protecting the American People Against Invasion (Jan. 20, 2025) (the...more

Miller Canfield

UPDATED: FinCEN’s New Interim Final Rule (1) Exempts Domestic Companies from Corporate Transparency Act Reporting and (2) Sets New...

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a new interim final rule (new IFR) significantly limiting the scope of reporting required under the...more

PilieroMazza PLLC

Corporate Transparency Act, Part 10: Interim Final Rule, U.S. Companies and U.S. Persons Exempt From Reporting

PilieroMazza PLLC on

On March 26, 2025, FinCEN issued an interim final rule and request for comments, removing the requirement under the Corporate Transparency Act (CTA) for both U.S. companies and U.S. persons to report beneficial ownership...more

Bradley Arant Boult Cummings LLP

FinCEN Exempts U.S. Entities from Reporting, but Uncertainty Remains

On March 21, 2025, the previous deadline to report Beneficial Ownership Information (BOI) to the Financial Crimes Enforcement Network (FinCEN) under the Corporate Transparency Act (CTA), FinCEN released an interim final rule...more

Epstein Becker & Green

CTA Interim Final Rule Eliminates Requirements for U.S. Companies and U.S. Individuals to File Beneficial Ownership Reports

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN), in an action that was promised earlier in March, issued an interim final rule (the “Interim Rule”) that removes all requirements for U.S. companies and...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Interim Final Rule Under the Corporate Transparency Act

On March 21, 2025, FinCEN released an interim final rule (the “Interim Final Rule”) that exempts domestic reporting companies and U.S. persons from being required to report beneficial ownership and company applicant...more

Herbert Smith Freehills Kramer

Updates to Registration Requirement for Foreign Nationals

Effective April 11, 2025, an Interim Final Rule promulgated by the Department of Homeland Security (DHS) amends existing regulations to require certain foreign nationals to complete a new online registration form, as well as...more

Holland & Knight LLP

Interim Final Rule Clarifies Tribal Entities Not Subject to Corporate Transparency Act

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The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury charged with administering the Corporate Transparency Act (CTA), issued an interim final rule on March 21, 2025, that exempts...more

Lathrop GPM

U.S. Entities and U.S. Persons Are No Longer Required to Make CTA Filings under CTA Interim Final Rule

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Consistent with our expectations as reported in our last Legal Update dated March 4, 2025, on March 26, 2025, the United States Department of the Treasury Financial Crimes Enforcement Network (“FinCEN”) published an interim...more

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