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Disclosure Requirements

White & Case LLP

California Climate Disclosure Laws: CARB Affirms Reporting Deadlines, but Delays Regulations that Would Clarify Applicability

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On May 29, 2025, the California Air Resources Board ("CARB") affirmed the statutory deadlines for disclosures under SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-related Financial Risk Act)....more

McDermott Will & Emery

CMS Requires Hospitals to Publish More Pricing Information, Signals Focus on Enforcement

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On May 22, 2025, the Centers for Medicare & Medicaid Services (CMS) released new guidance for compliance with the hospital price transparency rule and published a request for information (RFI) seeking ways to bolster hospital...more

Perkins Coie

Don’t Mind If I Do: Montana Says Hands Off Neural Data

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In May 2025, Montana enacted Senate Bill 163 (SB 163), amending that state’s Genetic Information Privacy Act (MGIPA) to include protections for neurotechnology data—namely, data collected from the activity of the central or...more

Jones Day

Could the SEC's Enforcement Spotlight Return to Executive Perks?

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The Securities and Exchange Commission ("SEC") is hosting a roundtable discussion on disclosures just weeks after reports of significant increases in executive perks....more

Latham & Watkins LLP

FCA’s Final Proposals for PISCES: A New Era for Private Market Trading

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On 10 June 2025, the FCA unveiled its final proposals for the Private Intermittent Securities and Capital Exchange System (PISCES), following a comprehensive consultation process. The proposals mark a significant step in the...more

Holland & Knight LLP

Florida Enacts Disclosure Requirements for "Operations Charge" at Food Service Establishments

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Florida's newly enacted Chapter 2025-113 introduces detailed disclosure requirements for automatic fees imposed by public food service establishments. The revised statute – codified at Section 509.214, Florida Statutes – aims...more

Paul Hastings LLP

SEC Concept Release on Foreign Private Issuer Eligibility: A Portent for the Foreign Private Issuer Regulatory Framework?

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On June 4, 2025, the SEC published a concept release in which the agency analyzes trends related to foreign private issuers (FPIs) and solicits extensive feedback regarding whether and how the definition of FPI should be...more

Robinson Bradshaw

Cancel Culture, FTC Style: What Subscription-Based Businesses Need to Know about the FTC’s New “Click-to-Cancel” Rule

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Last fall, the FTC published the Rule Concerning Recurring Subscriptions and Other Negative Option Programs, or the “Click-to-Cancel Rule.” The Rule targets practices where cancellation is intentionally more difficult than...more

Hogan Lovells

OFAC lifts certain sanctions on Syria, broad export controls remain in place

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General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more

BCLP

SEC Considers Modification of Foreign Private Issuer Criteria: May Result in Fewer Foreign Companies Qualifying as FPIs

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On June 4, 2025, the SEC released a Concept Release seeking public comment on potential changes to the definition of foreign private issuer (“FPI”), which changes may have the effect of reducing the number of foreign...more

Morrison & Foerster LLP

SEC Seeks Public Comment on Stricter Standards for Foreign Private Issuer (FPI) Reporting

On June 4, 2025, the U.S. Securities and Exchange Commission (SEC) issued a Concept Release soliciting public comments on whether and how to revise the definition of a foreign private issuer (FPI) under the federal securities...more

Stevens & Lee

CMS Issues Updated Hospital Price Transparency Guidance and Related RFI

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The Centers for Medicare & Medicaid Services (CMS) released new Updated Hospital Price Transparency Guidance (Guidance) to “strengthen the Hospital Price Transparency requirements, requiring hospitals to post the actual...more

Constangy, Brooks, Smith & Prophete, LLP

Company’s pay equity study is not privileged, court rules

A cautionary tale for employers. EDITOR’S NOTE: Our Affirmative Action Alert blog has been re-titled EEO Compliance Dispatch. Many companies proactively analyze employee compensation to ensure that any disparities...more

Foley & Lardner LLP

New Disclosure Requirements for Florida Resorts and Food Establishments

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Described as a law to make it easier to remove hotel guests who have not paid their bills, Florida Bill SB 606 (“the Bill”) includes several new required disclosures that will impact Florida restaurants, hotels, and...more

King & Spalding

CPPA Revises Draft Rules on Automated Decisionmaking Technology, Cybersecurity Audits, and Risk Assessments

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On May 1, 2025, the California Privacy Protection Agency (CPPA) released a revised draft of its regulations. These modifications, issued in response to public comments on earlier drafts, aim to clarify and simplify key...more

Foley & Lardner LLP

State Data Breach Notification Laws - June 2025

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While most state data breach notification statutes contain similar components, there are important differences, meaning a one-size-fits-all approach to notification will not suffice. What’s more, as data breaches continue to...more

Mayer Brown

New York Enacts First-of-Its-Kind Law to License Buy-Now-Pay-Later Lenders

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The regulatory environment for “Buy Now, Pay Later” (or “BNPL”) loans is entering a new era. On May 9, 2025, New York enacted legislation that will require providers of BNPL loans to be licensed by the state and adhere to...more

Mayer Brown Free Writings + Perspectives

SIFMA and Other Industry Groups Petition SEC for Recission of Cybersecurity Disclosure Requirement

In late May 2025, the Securities Industry and Financial Markets Association (SIFMA), together with the American Bankers Association, Bank Policy Institute, Independent Community Bankers of America, and Institute of...more

Jones Day

Civil Justice Council Recommends "Light Touch" Regulation of Litigation Funding in United Kingdom

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The Civil Justice Council ("CJC") has published its final report, recommending that the UK government regulate litigation funding and pass legislation to enable funders to be remunerated by way of a percentage of any damages...more

BakerHostetler

FTC’s Junk Fee Rule FAQs Give Road Map for Displaying Price

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In May the FTC’s Rule on Deceptive or Unfair Fees (the Rule) went into effect, and the FTC staff published accompanying FAQs for business. We have blogged a lot about the proposed Rule, enforcement in this space and its windy...more

Akin Gump Strauss Hauer & Feld LLP

Atkins-led SEC Recognizes that Conflicts of Interest must be “Material” in Complaint alleging Fraud and Breaches of Fiduciary...

SEC v. Nagler is the second enforcement action charging an investment adviser with undisclosed conflicts of interest since Chair Paul Atkins began his tenure on April 21, 2025. The Securities and Exchange Commission (SEC)...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

Orrick, Herrington & Sutcliffe LLP

Senators pen bipartisan letter arguing rescission of Treasury rule

On May 27, Sens. Sheldon Whitehouse (D-RI) and Charles Grassley (R-IA) wrote to the Treasury encouraging recission of the interim final rule requiring “foreign reporting companies,” but not domestic entities or U.S. citizens,...more

Orrick, Herrington & Sutcliffe LLP

Fed releases its Senior Financial Officer Survey results for March 2025

On May 30, the Fed released its results of its Senior Financial Officer Survey summarizing responses from bank officers regarding their reserve balance management strategies and practices. The survey concluded on March 31 and...more

Morgan Lewis

SEC Focus on the Life Sciences Industry: What to Expect and How to Prepare

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The life sciences sector remains a critical area of focus for the US Securities and Exchange Commission (SEC) under the current administration. Companies operating in the healthcare, pharmaceutical, biotechnology, and medical...more

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