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The Future of FOIA is Here: New Requirements under Acts 505 and 922 of 2025
The Arkansas Freedom of Information Act (FOIA) has long been a cornerstone of transparency, ensuring that the public has access to government records and meetings. Acts 505 and 922 of 2025, which took effect on August 5, 2025, significantly amend FOIA to modernize public meeting rules, clarify definitions, restrict substantive communications among governing body members, and create new procedures and penalties for violations....By: Mitchell, Williams, Selig, Gates & Woodyard,
SEC “Project Crypto”
The America First Policy Institute is a think tank with enormous influence on the Trump Administration. Members of the Institute have joined the administration in senior positions. So, it was fitting for Securities and Exchange Commission (SEC) Chairman Paul Atkins, a Trump appointee, to launch “Project Crypto” in a speech delivered to the Institute....By: Foley & Lardner LLP
SBA Proposes Bigger Size Standards: What It Means for Small Businesses
On August 22, the U.S. Small Business Administration (SBA) proposed an important change that could affect thousands of companies competing for federal contracts. In the proposed rule, the SBA suggested raising certain size standards used to determine when a company is considered “small.”...By: Bass, Berry & Sims PLC
California Climate Disclosure Laws: CARB Releases Draft Guidance on SB 261
On September 2, 2025, the California Air Resources Board ("CARB") released draft guidance on SB 261 (the Climate-related Financial Risk Act) called a "Draft Checklist" that entities can use in preparing their climate-related financial risk reports that are due by January 1, 2026 (the "Guidance")....By: White & Case LLP
Impact Allocator Perspectives 2025: Opportunities and Risks in Evolving Private Markets
We are grateful for the opportunity to collaborate with ICM on this inaugural LP Survey and value the insights gained from the survey’s participants. This survey offers fund managers a timely and actionable window into the evolving landscape of impact investing. By capturing the perspectives of leading allocators across a diverse array of institutions, this survey distills critical insights on asset class preferences, emerging impact themes, and the key risks and barriers shaping capital...By: Foley Hoag LLP
New Exchange Act Rules Compliance and Disclosure Interpretation 130.05
On August 27, 2025, the staff of the Securities and Exchange Commission (the “SEC”) published new Exchange Act Rules Compliance and Disclosure Interpretation 130.05, governing the treatment of certain former smaller reporting companies (“SRCs”) under the federal securities laws in the fiscal year after such a former SRC ceases to qualify as an SRC....By: Mayer Brown Free Writings + Perspectives
OFAC Compliance: Legal Framework, Enforcement Risks, and 2024–2025 Enforcement Developments
The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, is the agency responsible for enforcing U.S. economic and trade sanctions. Its activity covers U.S. citizens, green card holders, companies registered in the U.S., and in many cases, even their foreign subsidiaries. In fact, non-U.S. businesses and individuals can also face serious consequences if their actions cause a U.S. person or company to break sanctions....By: Friling Law
Análisis: Paquete Económico para el Ejercicio Fiscal 2026 en México
El Mtro. Édgar Amador Zamora, secretario de Hacienda y Crédito Público de México, el 8 de septiembre de 2025, entregó ante la Cámara de Diputados el Paquete Económico para el Ejercicio Fiscal 2026 (PE 2026), el cual incluye ......By: Holland & Knight LLP
Second Circuit Rules on Plaintiffs’ Standing and Prohibited Transaction Issues in 401(k) Class Action
The Second Circuit recently made two rulings of interest to ERISA litigators and to fiduciaries of 401(k) or other defined contribution plans. In the first ruling, the court held that individual plan participants did not have constitutional standing to assert claims of breach of fiduciary duties of oversight concerning funds in which the plaintiffs did not invest. In the second ruling, the court remanded to the district court the plaintiffs’ claims that certain plan contracts with service...By: Nutter McClennen & Fish LLP
AI Law Delayed to June 2026, What the Rental Housing and Financial Services Industries Can Do Next
On August 28, 2025, Governor Jared Polis signed the AI Sunshine Act (Senate Bill 25B 004) into law, moving the effective date of the Colorado Artificial Intelligence Act (CAIA; Col. Rev. Stat. § 6-1-1701) to June 30, 2026....By: Hudson Cook, LLP
A Cautionary Tale for Contractors: Illinois Court Strictly Enforces Cyber Exclusion
While cyber liability coverage decisions are usually few and far between, courts in two jurisdictions have issued buzzworthy rulings this summer. Originally published by CLM Magazine - September 9, 2025....By: Zelle LLP
2026 Economic Package
On Sept. 8, the Federal Executive Branch presented the Economic Package for 2026 (“EP 2026”), which includes various tax amendments, including the increase of certain taxes....By: Clark Hill PLC
DOJ Signals Approach to Digital Assets - What It Means for Developers and Platforms
On August 21, 2025, Acting Assistant Attorney General Matthew R. Galeotti delivered remarks at the American Innovation Project (AIP) Summit in Jackson, Wyoming. Mr. Galeotti’s remarks focused on the digital asset ecosystem and the Department of Justice’s (DOJ) enforcement priorities....By: WilmerHale
Paquete Económico 2026
El 08 de septiembre pasado, el Ejecutivo Federal presentó ante la Cámara de Diputados el Paquete Económico para el 2026 (“PE 2026”), mismo que contempla diversas modificaciones fiscales, incluyendo el alza de ciertos impuestos....By: Clark Hill PLC
Colombia regula la gestión de riesgos ambientales, sociales y climáticos en entidades financieras
Por medio del Proyecto de Circular Externa 0402 de 2025, la Superintendencia Financiera de Colombia (SFC) dio a conocer para comentarios del público, la normativa con la cual busca impartir instrucciones para que las entidades identifiquen y gestionen riesgos ambientales, sociales y climáticos. Asimismo, imparte las reglas particulares que se deben seguir para la gestión…...By: Holland & Knight LLP
FDIC updates its enforcement code providing leeway in terminating orders
On September 8, the FDIC announced it had updated chapter four of its Formal and Informal Enforcement Actions Manual, on Cease-and-Desist Actions, revising the minimum standards for terminating cease-and-desist and consent orders issued under Section 8(b) of the FDI Act. The latest update allows for greater discretion in terminating an order....By: Orrick, Herrington & Sutcliffe LLP
New perspectives on handling decommissioning liabilities & risks for end-of-life energy, mining, industrial, waste management and shipping assets
It is estimated that over the coming decades, decommissioning redundant and end-of-life energy, mining, industrial, waste management and shipping assets will cost at least USD 8 trillion. Including nuclear energy, only about USD 0.5 trillion of these liabilities have been pre-funded. So USD 7.5 trillion worth of decommissioning obligations solely rely on creditworthiness of their operator at the time of decommissioning....By: Hogan Lovells
District court denies earned wage access company’s motion to dismiss, class action claims to continue after finding that wage access product constitutes credit under TILA
On September 8, the U.S. District Court for the Western District of Washington denied an earned wage access provider’s motion to dismiss claims, ruling in favor of an individual alleging the fintech company of unlawful lending practices....By: Orrick, Herrington & Sutcliffe LLP
FinCEN updates its money reporting requirement min. from $200 to $1K
On September 8, the Treasury through FinCEN issued additional reporting requirements on financial institutions through its Geographic Targeting Order (GTO). This GTO will require certain money services businesses along the southwest border to file Currency Transaction Reports with FinCEN for cash transactions between $1,000 and $10,000 occurring in specific counties and ZIP codes, retain records of these currency transactions, and verify the identity of the individuals conducting the...By: Orrick, Herrington & Sutcliffe LLP
CFPB proposes to standardize Nonbanks’ ‘Risks to Consumers’
The CFPB is proposing a rule that standardizes determinations that nonbanks pose “risks to consumers,” a move that could result in fewer nonbanks being designated as posing risk and thus subject to CFPB supervisory jurisdiction....By: Ballard Spahr LLP
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