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Morrison & Foerster LLP

U.S. SEC Extends Compliance Deadline for Recent Amendments to the Customer Protection Rule

Morrison & Foerster LLP on

On June 25, 2025, the U.S. Securities and Exchange Commission (SEC) voted to extend the compliance deadline for recent amendments to Exchange Act Rule 15c3-3 (the “Customer Protection Rule”) to June 30, 2026. The amendments,...more

Brownstein Hyatt Farber Schreck

CFPB Changes Approach to Guidance

Brownstein Hyatt Farber Schreck on

On May 12, 2025, the Consumer Financial Protection Bureau (CFPB) announced a sweeping withdrawal of 67 guidance documents issued since the CFPB’s inception, signaling a marked shift in its regulatory approach. This move...more

Clark Hill PLC

How to Explain Automated Decisions: Recent CJEU Decision and CPPA Rulemaking Offer Insight into ADM Explainability

Clark Hill PLC on

Automated decision-making, or ADM, is used for a wide range of use cases that impact individuals — from processing insurance claims and credit scoring, to ranking job candidates and offering personalized pricing or targeted...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

Ropes & Gray LLP on

On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

Shook, Hardy & Bacon L.L.P.

California Jumps Into Privacy Rulemaking (Again)

Shook, Hardy & Bacon L.L.P. on

The California Privacy Protection Agency (CPPA) is starting formal rulemaking (again) as they move beyond the pre-rulemaking drafts that were debated for a little over a year. During their November 8, 2024, board meeting, the...more

Sheppard Mullin Richter & Hampton LLP

CFPB: Negative Option Marketing Practices May Violate CFPA

Sheppard Mullin Richter & Hampton LLP on

On January 19, the CFPB issued Circular 2023-01 to affirm that companies offering “negative option” subscription services are required to comply with federal consumer financial protection laws. According to the Circular,...more

Littler

Another Privacy Headache for California: Court of Appeal Ruling Will Slow Down Criminal Background Checks Throughout California

Littler on

Companies that hire employees and engage independent contractors in California should brace for a significant slowdown in background checks that include criminal record searches in California state courts....more

Littler

SEC Amends Whistleblower Award Program Rules

Littler on

With a vote split down party lines, on September 23, 2020, the Securities and Exchange Commission (SEC) approved several amendments to rules governing its Whistleblower Program. The purpose of the amendments, according to the...more

Epstein Becker & Green

Time Is Money: A Quick Wage-Hour Tip on … Joint Employer Status Under the Fair Labor Standards Act

Epstein Becker & Green on

With the March 16, 2020 effective date of the new rule interpreting joint employer status under the Fair Labor Standards Act (“FLSA”) almost upon us, employers should brush up on the updated guidance and review their...more

Jones Day

DOJ Limits the Use of Agencies' Guidance Documents in Civil Enforcement Actions

Jones Day on

The Department of Justice ("DOJ") recently issued a memorandum limiting the ability of its litigators to use agency guidance documents in civil enforcement actions against private parties. The memo expands on a directive...more

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