News & Analysis as of

Reporting Requirements Rulemaking Process

BakerHostetler

The Delayed, but Not Forgotten, Disclosure of PFAS: TSCA Section 8(a)(7) Postponed While States Fill the Gaps

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When Congress passed the fiscal year 2020 National Defense Authorization Act (“NDAA”), it included a mandate that the U.S. Environmental Protection Agency (“EPA”) take steps to require all manufacturers, including importers,...more

Akin Gump Strauss Hauer & Feld LLP

SEC to Consider Changes to “Foreign Private Issuer” Eligibility Criteria

On June 4, 2025, the U.S. Securities and Exchange Commission (the “SEC”) published a concept release soliciting public comment on potential changes to the definition of “foreign private issuer” (“FPI”)....more

Beveridge & Diamond PC

EPA’s Path Forward on TSCA Becomes Clearer

After a period of uncertainty, how the U.S. Environmental Protection Agency (EPA) plans to revise its implementation of the Toxic Substances Control Act (TSCA) during the second Trump administration is coming into focus...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Requests Public Comment on the Definition of Foreign Private Issuer

On June 4, 2025, the Securities and Exchange Commission (SEC) issued a concept release soliciting public input on whether the definition of foreign private issuer (FPI) should be amended, particularly given the significant...more

Wilson Sonsini Goodrich & Rosati

SEC Solicits Public Input on Definition of Foreign Private Issuer

On June 4, 2025, the U.S. Securities and Exchange Commission announced that it published a concept release to solicit public comment on the definition of foreign private issuer (FPI). FPIs benefit from a number of...more

Jones Day

California Air Resources Board Offers Direction as to Application of California Climate Disclosure Laws

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On May 29, 2025, a virtual public workshop held by the California Air Resources Board ("CARB") offered direction on how it interprets certain elements of California's climate disclosure laws. While CARB has a July 1, 2025,...more

Troutman Pepper Locke

CARB Workshop on Climate Disclosure Laws: More Questions Than Answers

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On May 29, 2025, the California Air Resources Board (CARB) held a virtual public workshop to review and discuss its rulemaking response to California Senate Bills (SBs) 253, 261, and 219, which require companies that “do...more

Cooley LLP

FCC Proposes Rules to Ferret Out Control of Regulated Entities by Foreign Adversaries

Cooley LLP on

The Federal Communications Commission (FCC) has released a notice of proposed rulemaking on control of FCC-regulated businesses by “foreign adversaries.” If the FCC adopts these rules, nearly every entity that is subject to...more

Fenwick & West LLP

Takeaways from CARB’s Virtual Workshop Regarding California’s Corporate Climate Disclosure Rules

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On May 29, 2025, The California Air Resources Board (CARB) held a virtual workshop to “support the development of California’s Corporate Greenhouse Gas Reporting Program” reflected in the Climate Corporate Data Accountability...more

Fox Rothschild LLP

Initial Concepts Provided on California Climate Disclosure Laws Implementation

Fox Rothschild LLP on

The regulations for the California Climate Corporate Data Accountability Act (SB253), which applies to entities with annual revenue in excess of $1 billion, have been delayed until the end of 2025. The California Air...more

Bergeson & Campbell, P.C.

Minnesota Extends Public Comment Period on Proposed PFAS Reporting Rule as Entities Voice Concerns about Compliance with Deadlines...

On May 22, 2025, the Minnesota Pollution Control Agency (MPCA) held a public hearing on its “Proposed Permanent Rules Relating to PFAS in Products; Reporting and Fees” (proposed rule). Administrative Law Judge (ALJ) Jim...more

Ropes & Gray LLP

Complying With California’s New Climate Disclosure Laws – Takeaways for Reporting Companies from the California Air Resources...

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The California Air Resources Board held an almost four hour virtual public workshop on May 29 on California’s pending climate risk and greenhouse gas emissions disclosure laws. The stated purpose of the workshop was to...more

Bergeson & Campbell, P.C.

Chemical Coalition Withdraws TSCA Section 21 Petition Seeking Revisions to TSCA 8(a)(7) PFAS Reporting Rule

As reported in our May 4, 2025, blog item, on May 2, 2025, a coalition of chemical companies petitioned the U.S. Environmental Protection Agency (EPA) for an amendment of the Toxic Substances Control Act (TSCA) Section...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

Orrick, Herrington & Sutcliffe LLP

CFPB requests comment on its consumer complaint intake form

On May 22, the CFPB published a notice in the Federal Register requesting comments on the extension of the Consumer Complaint Intake System Company Portal Boarding Form. The Dodd-Frank Act requires the CFPB to facilitate the...more

Latham & Watkins LLP

Latest Developments in Fight Over California’s Climate Disclosure Laws

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A preliminary injunction motion is set for May, the judge issued a scheduling order, and CARB announced a public workshop to kick off a rulemaking to implement the laws....more

Mayer Brown

CVM Abre Consulta Pública para Discutir o Aprimoramento das Regras de Divulgação de Informações ao Mercado por Companhias Abertas

Mayer Brown on

A Comissão de Valores Mobiliários (CVM) divulgou, em 13 de maio de 2025, o Edital de Consulta Pública SDM n.º 01/25 (Edital), que submete à apreciação do mercado proposta de substituição integral da Resolução CVM n.º 44/21,...more

Troutman Pepper Locke

CFPB Proposes Rescission of Nonbank Registration Rule

Troutman Pepper Locke on

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more

Farella Braun + Martel LLP

EPA Announces Interim Rule Further Delaying TSCA Section 8(a)(7) PFAS Reporting by Nine Months

On May 12, 2025, EPA announced that it will publish an interim rule further delaying by nine months the one-time reporting required under TSCA section 8(a)(7) for entities manufacturing or importing PFAS at any time between...more

Carlton Fields

Implementing Executive Order, FTC Calls on Public and Regulated Community to Identify Anticompetitive Regulations for Potential...

Carlton Fields on

The second Trump administration has issued a slew of deregulatory measures aimed at turbocharging the reduction of regulatory bloat (EO 14192, requiring the repeal of 10 regulations for every new one issued), ensuring...more

Eversheds Sutherland (US) LLP

SEC extends security-based swap reporting requirements safe harbor to 2029

On April 17, 2025, the Securities and Exchange Commission (SEC) extended the expiration date of a no-action statement (Compliance Statement) regarding compliance with reporting rules for security-based swap data repositories...more

BCLP

PFAS Announcement; Administrator Zeldin Signals Continuation of EPA Objectives

BCLP on

On April 28, 2025, EPA Administrator Zeldin issued the Agency’s most comprehensive statement since Trump’s inauguration regarding how EPA plans to address PFAS compounds under a variety of ongoing regulatory programs (“EPA...more

McDermott Will & Emery

IRS Roundup April 1 – April 17, 2025

The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax...more

Fenwick & West LLP

CARB to Hold Virtual Public Workshop Regarding California’s Corporate Climate Disclosure Rules

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The California Air Resources Board (CARB) has announced that it will hold a virtual public workshop to “support the development of California’s Corporate Greenhouse Gas Reporting Program,” as reflected in The Climate...more

Proskauer - Regulatory & Compliance

CSRD’s ESRS Draft Work Plan Faces Rejection At Latest EFRAG Meeting

On 15 April 2025, the sustainability reporting board (“SRB”) of the European Financial Reporting Advisory Group (“EFRAG”) failed to agree to an internal timeline for delivering advice to the European Commission on the...more

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