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Reporting Requirements Comment Period Proposed Rules

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

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The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more

Holland & Knight LLP

A Little Breathing Room for Product Importers: EPA Extends TSCA 8(a)(7) Reporting Deadline

Holland & Knight LLP on

While product importers were spending the summer poring over the Instructions for Reporting PFAS Under TSCA Section 8(a)(7) (May 2024), the U.S. Environmental Protection Agency (EPA) was working on a Direct Final Rule and...more

Venable LLP

FDIC Finalizes Large Bank Resolution Plan Rule and OCC Proposes Changes to Recovery Plans

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The FDIC recently finalized its resolution planning rule for large banks, which becomes effective October 1, 2024. Resolution plans, or "living wills," are plans to wind down operations in the event of bank failures. The...more

Schwabe, Williamson & Wyatt PC

Comments Sought on Proposed Requirements of the Cyber Incident Reporting for Critical ‎Infrastructure Act

On March 15, 2022, the Cyber Incident Reporting for Critical Infrastructure Act of 2022 was signed into law. Generally, CIRCIA requires “covered entities,” defined as entities in certain critical infrastructure sectors, to...more

Foley Hoag LLP - Security, Privacy and the...

Deadline to Comment on Proposed Rules Impacting Infrastructure as a Service Providers Approaching

On January 29, 2024, BIS proposed a rule that would impose new requirements for U.S. providers of Infrastructure as a Service (“IaaS”) products and their foreign resellers. The proposed rule would require U.S. IaaS providers...more

Woods Rogers

Proposed Federal Cyber Incident Reporting Rule Adds Hefty Federal Reporting Requirements to Critical Infrastructure Sector and...

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The federal Cybersecurity and Infrastructure Security Agency (CISA) released a draft of its proposed rule detailing how covered entities operating in critical infrastructure sectors report cyberattacks and ransomware payments...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Troutman Pepper

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

Troutman Pepper on

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

White & Case LLP

SEC Reopens Comment Period on Proposed Rule Amendments to Modernize Beneficial Ownership Reporting

White & Case LLP on

On April 28, 2023, the Securities and Exchange Commission ("SEC") reopened the comment period for proposed amendments to modernize the rules governing beneficial ownership reporting under the Securities Exchange Act of 1934...more

Mayer Brown Free Writings + Perspectives

SEC Reopens Comment Period for Proposed Rule Amendments to Modernize Beneficial Ownership Reporting

On April 28, 2023, the Securities and Exchange Commission announced that it was reopening the comment period for the proposed amendments to modernize the rules governing beneficial ownership reporting filed on Schedules 13D...more

Bergeson & Campbell, P.C.

EPA Seeks Comment on Initial Regulatory Flexibility Analysis on Proposed PFAS Reporting Rule

On November 25, 2022, the U.S. Environmental Protection Agency (EPA) announced the availability of and solicited comment on an Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis following the...more

Beveridge & Diamond PC

EPA Hints at Critical Changes to TSCA PFAS Reporting Rule, Seeks Comment

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The U.S. Environmental Protection Agency's (EPA) June 2021 proposal of a Toxic Substances Control Act (TSCA) reporting rule targeting manufacturers of per- and polyfluoroalkyl substances (PFAS) sparked a major outcry from...more

Wilson Sonsini Goodrich & Rosati

SEC Reopens Comment Periods for Certain Rulemaking Releases

On October 7, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it will reopen the public comment periods for 11 rulemaking releases and one request for comment due to a technological error that resulted...more

Fisher Phillips

State Officials Voice Support for OSHA’s Proposed Recordkeeping Rule – And Call for It to Go Even Further

Fisher Phillips on

A coalition of state Attorneys General, led by New Jersey’s acting Attorney General Matthew Platkin, just submitted a letter to Labor Secretary Marty Walsh not only supporting OSHA’s proposed injury and illness reporting rule...more

Goodwin

Draft Implementing Rules of China’s Human Genetic Resources Regulations as Applied to Foreign Persons

Goodwin on

The Administrative Regulations of the People’s Republic of China on Human Genetic Resources (the “Regulations”), promulgated by China’s State Council, have been in effect for almost three years. As the administrative...more

Fenwick & West LLP

SEC Proposes New Rules to Enhance Reporting of Cybersecurity Issues

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The U.S. Securities and Exchange Commission has proposed rules and amendments to enhance and standardize the reporting on cybersecurity risk management, strategy, governance and incidents disclosed by public companies....more

Goodwin

SEC Proposes Short Sale Disclosure Rule and Reopens Comment Period for Reporting on Securities Loans

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more

Perkins Coie

SEC Proposes New Cybersecurity Risk Management Regime for Registered Funds and Advisers

Perkins Coie on

In today’s asset management landscape, cybersecurity threats are omnipresent, and with constantly evolving tools of attack, actual breaches have become increasingly prevalent. As the complexity, scope, and frequency of cyber...more

Goodwin

Stress Test Scenarios Released for 2022

Goodwin on

In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Changes to Beneficial Ownership Reporting

On February 10, 2022, the U.S. Securities and Exchange Commission (SEC) voted 3-1 to approve proposed changes to public company beneficial ownership reporting requirements. The SEC has long considered such changes to the...more

Jones Day

SEC's Proposed Rules Target Advisers to Private Funds

Jones Day on

On February 9, 2022, the SEC proposed new rules focused on private fund advisers' practices, reporting, and disclosures ("Proposed Rules"). The Proposed Rules would apply to all SEC registered advisers to private funds, and a...more

Goodwin

SEC Cybersecurity Rules Target Investment Advisers and Investment Companies

Goodwin on

On February 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed a package of new rules and amendments to enhance cybersecurity preparedness and improve cyber resilience of investment advisers and investment...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes New Disclosure Rule for Security-Based Swap Positions

On December 15, 2021, the Securities and Exchange Commission (SEC) voted 3-2 to approve proposed rules that, among other things, would add new Rule 10B-1 to require a prompt disclosure of large security-based swap (SBS)...more

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