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Reporting Requirements Rulemaking Process

Proskauer Rose LLP

SEC Releases Statement on Short Sale and Securities Lending Rules Following Remand by 5th Circuit U.S. Court of Appeals

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A three judge panel of the U.S. Court of Appeals for the Fifth Circuit recently remanded two rules adopted by the SEC in 2023 for further consideration – Rule 13f‑2 (the short sale rule) and Rule 10c1‑a (the securities...more

Fenwick & West LLP

Securities Law Update - September 2025

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Welcome to the latest edition of Fenwick’s Securities Law Update. This issue contains updates and important reminders on...more

Proskauer Rose LLP

SEC Releases Unsurprising But Ambitious Spring 2025 Regulatory Agenda

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This week, the Securities and Exchange Commission (the “SEC”) published its semiannual Regulatory Flexibility Agenda (“Reg Flex Agenda”), detailing its short-term and long-term rulemaking priorities for the year. The SEC is...more

Wilson Sonsini Goodrich & Rosati

Takeaways from CARB’s Workshop on California’s Corporate Greenhouse Gas Reporting Program

In late August 2025, the California Air Resources Board (CARB) held its second virtual public workshop to support the development of California’s corporate greenhouse gas (GHG) reporting and climate-related financial risk...more

Baker Donelson

Fifth Circuit Sends Back SEC's Securities Lending and Short Sale Rules for Agency to Consider Cumulative Economic Impact

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In a decision that could reshape how securities lending and short sale market transactions are disclosed, the U.S. Court of Appeals for the Fifth Circuit (the Court) returned two key Securities and Exchange Commission (SEC)...more

Quarles & Brady LLP

Alabama Board of Pharmacy Issues Non-Disciplinary Fine Schedule

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On August 20, 2025, the Alabama Board of Pharmacy (the “Board”) issued its long-awaited non-disciplinary penalty schedule via emergency rulemaking. The rule went into effect immediately and will expire on December 18, 2025....more

Bergeson & Campbell, P.C.

EPA Submits Proposed Rule Revising TSCA Section 8(a)(7) PFAS Rule to OMB for Review

According to the Office of Management and Budget (OMB) website, on August 29, 2025, the U.S. Environmental Protection Agency (EPA) submitted a proposed rule entitled “Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data...more

K&L Gates LLP

Companies Must Prepare for Complying With California's Climate Disclosure Laws Even Though California Air Resources Board...

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The 2026 reporting deadlines are quickly approaching for California’s Climate Corporate Data Accountability Act (SB 253) and Climate-Related Financial Risk Act (SB 261). The California Air Resources Board (CARB), responsible...more

Orrick, Herrington & Sutcliffe LLP

Congressional researchers note one-year mark since proposed financial data rule

On August 25, the Congressional Research Service (CRS) released a report detailing the implementation status of joint agency data standards required under the Financial Data Transparency Act (FDTA). The FDTA requires agencies...more

Hogan Lovells

California accelerates towards GHG Disclosures in advance of 2026 Deadlines with Regulatory Timeline and Litigation Win (SB 253...

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The California Air Resources Board (CARB) is forging ahead in implementing what the Agency now refers to as “the 200s”—the Climate Corporate Data Accountability Act (SB 253) and the Climate Related Financial Risk Act (SB...more

Pillsbury Winthrop Shaw Pittman LLP

Court Declines to Halt Climate Disclosure Laws as CARB Pursues Delayed Rulemaking

New laws take effect January 1 while regulated entities still await implementing regulations from California Air Resources Board....more

Orrick, Herrington & Sutcliffe LLP

SEC Short Interest and Securities Lending Reporting Rules Remanded

On August 25, the United States Court of Appeals for the Fifth Circuit remanded two rules adopted by the Gensler-era SEC: the Securities Lending Reporting Rule and the Short Interest Reporting Rules (the Rules). While the...more

Holtzman Vogel Baran Torchinsky & Josefiak

Universities Face Stricter Data Reporting Requirements Under New Trump Policy

On August 7, 2025, President Trump signed a Presidential Memorandum to require greater transparency regarding university admissions practices. The Memorandum reinforces previous executive orders and memoranda regarding DEI...more

Cooley LLP

CARB Workshop Provides Additional California Climate Law Disclosure Guidance

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The California Air Resources Board (CARB) held a virtual public workshop on August 21 to refine implementation of the state’s corporate climate-disclosure laws – Senate Bills 253 and 261 (amended by SB 219). In advance of...more

Vinson & Elkins LLP

CARB Hosts Public Workshop on California Climate Laws

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The California Air Resources Board (“CARB”) hosted a public workshop on August 21, 2025 to provide information on Senate Bills 253, 261 and 219 (the “California climate laws”) and solicit feedback from consumers and...more

Ropes & Gray LLP

California Air Resources Board Addresses the Who, What, How and When of California’s Corporate Climate Disclosure Laws at August...

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Yesterday, the California Air Resources Board held its second marathon virtual public workshop on California’s pending corporate climate disclosure laws. These laws will require subject companies to publicly report on...more

Cooley LLP

SEC Executive Compensation Roundtable Comment Letter Roundup

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As described in this June 27 alert, the Securities and Exchange Commission (SEC) on June 26 hosted a roundtable meeting to discuss potential updates to the existing executive compensation disclosure requirements and solicited...more

Kelley Drye & Warren LLP

Reminder: Federal Communications Commission – August and September Filings 2025

Each month, Kelley Drye’s Communications Group offers this reminder of upcoming filing deadlines that may affect our clients and friends. The successor to the Form 477 Local Competition and Broadband Report, the BDC Report...more

Venable LLP

CFPB Reviewing Consumer Reporting Larger Participant Rule

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The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether its 2012 "larger participant" rule for the consumer reporting market continues to capture the most significant market actors in light of industry...more

Bradley Arant Boult Cummings LLP

GAO Issues a New Bid Protest Pleading Standard

In a recent decision, the Government Accountability Office (GAO) clarified its minimum pleading standard for bid protests. The decision was a bit unusual because, unlike the courts, the GAO rarely uses published decisions to...more

Troutman Pepper Locke

Clarity on California’s Climate Disclosure Rules Could Be on the Horizon

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As the January 1, 2026, deadline to make the first required disclosure under California’s landmark climate laws approaches, the California Air Resources Board (CARB) has announced that it will host another virtual public...more

Baker Donelson

California's Climate Laws: CARB Sets the Stage, but Final Rules Delayed

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California is gearing up to implement and enforce two groundbreaking climate disclosure laws – the Climate Corporate Data Accountability Act (CCDA) and the Climate-Related Financial Risk Act (CFRA). In July 2025, in lieu of...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Issues Order Delaying Effective Date of Investment Adviser Rule

Following an earlier announcement on July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), on August 5, 2025, issued an Exemptive Relief Order (“Order”) to delay for two years,...more

Davis Wright Tremaine LLP

FCC Waives Requirement for Broadcasters to File Biennial Ownership Reports for 18 Months

Licensees of commercial and non-commercial full-power television, Class A television, low power television, AM radio, and FM radio stations are usually required to file biennial ownership reports with the Commission in...more

Orrick, Herrington & Sutcliffe LLP

CFPB scraps rule allowing states to enforce the CFPA without notice

On July 21, the CFPB published a notice in the Federal Register withdrawing its direct final rule that would have rescinded procedures requiring state officials to notify the Bureau when taking action to enforce the CFPA. As...more

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