29 Sep, 2022 FTC solicits feedback on advance notice of proposed rulemaking related to commercial surveillance and data security practices By Elizabeth Casale James Shreve Luke Sosnicki On August 22, 2022, the Federal Trade Commission (“FTC”) published an advance notice of proposed rulemaking (“ANPR”) that requests...
23 Sep, 2022 CMS seeks stakeholder feedback on COVID-19 waivers in new request for information By Catherine Feorene On September 6, 2022, the Centers for Medicare & Medicaid Services (CMS) released a Request for Information (RFI) seeking public input to...
09 Sep, 2022 The best way to keep one’s word is not to give it; “nonbinding” usually means nonbinding By Jeff Brown There can be a fine line between an unenforceable agreement to agree and an enforceable agreement with set terms. The Fourth District...
06 Sep, 2022 Proposed Regulation ZZ’s LIBOR transition rules for tough legacy contracts By Sarah Wade Sam Brand Garrett Fischer The London Interbank Offered Rate (“LIBOR”) has been the dominant interest rate benchmark around the globe for some time. Following the...