News & Analysis as of

Regulatory Requirements Time Extensions

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

OFCCP Extends Comment Period for Section 503 and VEVRAA Proposed Rulemakings and Rescission of EO 11246 Rules

On September 4, 2025, the Office of Federal Contract Compliance Programs (OFCCP) issued updates regarding the extension of comment periods for proposed rulemakings related to Section 503 of the Rehabilitation Act of 1973 and...more

WilmerHale

PCAOB Delays Implementation of QC 1000 Until December 2026

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The Public Company Accounting Oversight Board (PCAOB) announced yesterday that the effective date for QC 1000, A Firm’s System of Quality Control, would be delayed until December 15, 2026, though audit firms may elect to...more

Greenbaum, Rowe, Smith & Davis LLP

New Jersey BPU Takes Action on Community Solar & Competitive Solar Incentive Programs: Interesting Comments from the Bench

On August 13, 2025, at the New Jersey Board of Public Utilities’ (Board or BPU) regularly scheduled Agenda Meeting, the Board voted 3-0 to extend the deadlines for completion of construction for community solar projects as...more

Fenwick & West LLP

FinCEN Delays Investment Adviser AML/CFT Rule to January 2028: What Fund Managers Should Know

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of its 2024 investment advisor AML rule for registered investment...more

BCLP

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

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FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Benesch

Off-Cycle Medicare Revalidations for SNFs – Deadline Extended Again to January 1, 2026

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On July 17, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced via a Medicare Learning Network (“MLN”) update that the deadline for submission of mandatory off-cycle Medicare revalidations...more

Jones Day

ESRS Simplification: Updated Timeline and Expectations

Jones Day on

The European Commission has extended the deadline for the European Financial Reporting Advisory Group (EFRAG) to submit its technical advice on simplifying the European Sustainability Reporting Standards (ESRS) under the...more

Akin Gump Strauss Hauer & Feld LLP

Minnesota to Delay PFAS Reporting Deadline

Earlier this week, the Minnesota Pollution Control Agency (MPCA) announced it will extend the upcoming reporting deadline under the state’s PFAS-in-Products law. As currently written, the law requires manufacturers of...more

Holland & Knight LLP

EPA Extends TSCA Reporting Submission Deadline for 16 Substances

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The U.S. Environmental Protection Agency (EPA) finalized a rule to extend the deadline for manufacturers and importers of 16 chemicals to report certain unpublished health and safety studies to the EPA as required by a...more

Womble Bond Dickinson

FTC Defers Some Click-to-Cancel Rule Enforcement to July 14, 2025

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Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more

Cozen O'Connor

Deadline Extended for New York City Local Law 97

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May 1, 2025, was the first compliance report deadline under New York City’s Local Law 97 (LL97). LL97 requires most buildings over 25,000 square feet, including condominiums (condos) and cooperatives (coops), to limit carbon...more

Venable LLP

The FTC Defers Compliance Deadline for Updated Negative Option Rule to July 14 - A Fast VAST Update​​

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On Friday, ​the Federal Trade Commission voted to defer the compliance deadline for the amended Negative Option Rule by 60 days. The Commission issued a statement on the new deadline....more

BakerHostetler

FTC Delays Enforcement of Negative Option Rule Until July 14

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The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more

Venable LLP

FCC Approves Narrow Delay of New TCPA Revocation Rule

Venable LLP on

On April 7, the Federal Communications Commission (FCC) granted a limited waiver delaying by an additional year the effective date of certain parts of the new Telephone Consumer Protection Act (TCPA) rule. ...more

Troutman Pepper Locke

FCC Grants Limited One-Year Extension for TCPA Robocall Revocation Rule Compliance

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The Federal Communications Commission (FCC) issued an order extending the effective date of certain parts of § 64.1200(a)(10) of its rules under the Telephone Consumer Protection Act (TCPA) to April 11, 2026....more

BCLP

Pause for Effect: Current Corporate Transparency Act Deadlines will not be Enforced

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Although the Corporate Transparency Act (the “CTA”) remains in full force and effect and, along with it, a requirement for most reporting companies to file their beneficial ownership information reports, the previously...more

BakerHostetler

CTA Back in Effect; New Reporting Deadline of March 21

BakerHostetler on

On Feb. 17, the Texas federal district court in Smith v. U.S. Department of the Treasury granted the government’s motion for an immediate stay pending appeal of the nationwide order staying the effective date of the final...more

WilmerHale

Corporate Transparency Act: It’s Still Paused (For Now)

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Entities subject to the Corporate Transparency Act’s beneficial ownership information reporting requirement are not currently required to file BOI reports. Beyond that, much remains in flux regarding whether and when...more

Ruder Ware

The CTA Journey – It Goes On and On and On

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The Corporate Transparency Act (“CTA”) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuit’s motions panel, had its reporting deadlines...more

Sullivan & Worcester

Breaking: Corporate Transparency Act on Hold Again

Sullivan & Worcester on

Late on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own decision from earlier in the week, reinstating the nationwide preliminary injunction preventing the enforcement of the Corporate...more

UB Greensfelder LLP

Fifth Circuit Court of Appeals Reinstates Nationwide Injunction Blocking Enforcement of the Corporate Transparency Act

UB Greensfelder LLP on

On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This decision was made to "preserve the constitutional...more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Filings Are Back on Hold

In an unusual turn of events, the Fifth Circuit Court of Appeals has reversed itself and put the Corporate Transparency Act (CTA) back on hold....more

Eversheds Sutherland (US) LLP

Fifth Circuit changes course—CTA preliminary injunction reinstated

On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more

Benesch

On Hold AGAIN - CTA Preliminary Injunction Reinstated

Benesch on

As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...more

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