Publication - 02/28/2012

Congress Gives the Green Light to Incentive Auctions

Telecommunications Alert

On February 17, both the House and the Senate passed the Middle Class Tax Relief and Job Creation Act of 2012. Among other things, the Act provides for the extension of the payroll tax holiday and unemployment benefits and prevents cuts in Medicare physician payment rates. To help offset the cost of the Act, the legislation includes significant spectrum provisions centered around preparations and details of a future auction of spectrum currently held by broadcast television licensees to other users, likely including commercial wireless carriers. This process is ultimately expected to raise billions of dollars for the Treasury, while also helping to fund the creation of a nationwide public safety broadband network for emergency first responders, another subject of the Act.

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FinCEN Proposes New Rules for Investment Advisers

Investment Management Alert

The Financial Crimes Enforcement Network, which is a bureau of the Department of the Treasury, has proposed rules that would designate SEC-registered investment advisers as “financial institutions” under Bank Secrecy Act (BSA) regulations.

Pension Factoring Companies in Regulator Crosshairs

Client Alert
Zachary Z. Augustine, Stephen C. Baker, Michael J. Miller

For two decades, factoring companies buying structured settlement periodic payments in exchange for heavily discounted lump sums have done their best to avoid the anti-assignment language in underlying settlement documents.

Obama Board Reaffirms Successor’s Right to Set Initial Terms of Employment when Taking Over Unionized Operation

Client Alert
Gerald T. Hathaway

Last week, the National Labor Relations Board issued a refreshingly employer-friendly decision which allowed a successor company to implement new pay terms without having to first bargain with the labor union.

CBP Requesting Comments on Collection of Trusted Trader Information

Client Alert
Kathleen M. Murphy, Mollie D. Sitkowski

On Monday, August 31, 2015, U.S. Customs and Border Protection (CBP) announced it will be collecting comments on the draft application for its Trusted Trader Program (the Program).

The NLRB Expands the Definition of “Joint Employer”


William R. Horwitz, Philippe A. Lebel

Yesterday, the National Labor Relations Board (the “NLRB” or “Board”) issued a decision greatly expanding the standard for determining whether a company may be deemed a “joint employer.”