We have advised or are advising clients on more than 150
comment letters on some of the most important proposed reform regulations.
NAR had requested a federal exemption for real estate practitioners
in comment letters to both the FTC and FCC, lobbying both commissions diligently on the issue of restrictive telemarketing rules, but the only exemptions that ended up in the final rules were for political organizations, charities, telephone surveyors, and those with an existing business relationship.
NAR, as part of the Commercial Properties Coalition, recently filed the latest in a series
of comment letters relating to efforts by the U.S. Environmental Protection Agency (EPA) to regulate purported lead paint hazards that may arise from renovation and remodeling activities in public and commercial buildings.
McNabb gave credit to the DOL for taking into consideration all viewpoints
from comment letters on its proposed rule, and though the final version is not perfect, «it is workable and implementable and actually net - net it will be a positive thing for the industry in the long run.»
Natural Resources Defense Council (NRDC), National Wildlife Federation, National Environmental Trust, Union of Concerned Scientists, U.S. Public Interest Research Group, World Wildlife Fund, and Minnesotans for an Energy Efficient Economy,
Joint Comment Letter, June 5, 2002:
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IB
Group Comment Letter to SEC in Support of Amended Boston Options Exchange Trading Rules September 16, 2003
NASDAQ wrote three
separate comment letters insisting that the SEC reject IEX's exchange application, and they met with them several times as well.
Smelling blood in the water, the U.S. Chamber of Commerce (COC)-- a long - time opponent of the Fiduciary Rule - responded to the DOL with a highly -
critical comment letter.
Fujian Drug Price Reform Letter: Letter seeking delayed implementation of drug price reform pilot Read the
full comment letter...
In our
second comment letter to the SEC, we offer a potential solution that startups should be able to «test the waters» to gather interest before these requirements come into place.
Right now I am working on an adult novel and I have a very
nice comment letter from Kelley Armstrong, one of my favorite authors.
Culver City then submitted an impacted
party comment letter to the Public Works Committee making the assertion that the proposed exemption was illegal since it was «improperly piecemealing» a very large project into a set of related smaller components.
The Mann, Schmidt, and
Rutherford comment letter (hereinafter referred to as MS&R let2010) concerning elements of the McShane and Wyner 2010 paper for the Annals of Applied Statistics (hereinafter referred to as the M&W 2010 paper) is a marvel of fallacious arguments and circular logic.
In a law journal article and
regulatory comment letter, I also make the case that the administration's fuel - economy agenda trashes the separation of powers and administrative procedures.
Gavin Schmidt, Michael Mann, and Scott Rutherford (apparently representing the Team) have written a
scathing comment letter to the Annals of Applied Statistics about the recent allegedly «hockey - stick busting» paper by the naïve statisticians McShane and Wyner entitled A Statistical Analysis of Multiple Temperature Proxies: Are Reconstructions of Surface Temperatures Over the Last 1000 Years Reliable?
We were the auditor of record for the Company throughout the IPO process and assisted the team with navigating the Securities and Exchange Commission (SEC) filing process, providing practical real time guidance on the
SEC comment letter process with their registration statement enabling the Company to go to market in the time frame originally mapped out in the marketing plan.
Deliver excellence in customer service, receiving 10 positive
customer comment letters on average each month, earning a certificate of recognition and pin from company leadership.
NAR's
comment letter observes that seller financing is only subject to the section 129C ability - to - repay requirements if the seller provides financing more than five times in a calendar year and, therefore, would be considered a creditor.
In its
official comment letter in February of 2011, NAR supported «continued efforts to combat money laundering and the financing of terrorism.»
In
previous comment letters to the EPA on this issue, NAR recommended that the Agency not move forward with lowering the permitting thresholds, because of the fact that large office and apartment buildings could be included and be required to obtain a permit to emit CO2, which would have a detrimental impact on commercial real estate markets and economic development.
Despite
multiple comment letters submitted to the Agencies requesting greater clarity, the Rule's took effect on January 1, 2015.
In fact, CAARE may be the only consumer group that chimed in among the thousand or
so comment letters submitted by industry participants.
«Imposing further restrictions on the Enterprises» multifamily mortgage activities effectively denies the government the ability to recoup borrowed capital that would otherwise be generated from the strong performance of the multifamily business,» said the NMHC /
NAA comment letter.
The Feb. 21
comment letter requests clarification to ensure the real estate exception operates as intended for common real estate ownership arrangements — focusing on the scope and application of the exception for an electing real property trade or business.
In a series
of comment letters, I debated the Electric Power Industry Climate Initiative (EPICI) on the legality of early action crediting.
After a 1999 injunction was issued against the first permit authorization, and after the Corps reissued the permit in 2007 despite EPA concerns, EPA completed an extensive review of new scientific information and 50,000 written
public comment letters.
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IB
Group Comment Letter to SEC in Support of PCX Plus Electronic Option Trading System December 9, 2002
Submission to the TSX re:
Comment letter on proposed TSX amendments re disclosure of security based compensation arrangements
Clarke says the SEC will take into account each and
every comment letter submitted, and they need to know that funding portals are ready to launch as soon as equity crowdfunding becomes legal.
The more than 480
comment letters we received raised a number of important issues, focused on the best ways to protect investors while ensuring that securities - based crowdfunding is a workable path for raising capital by smaller companies,» said White in her opening testimony at today's confirmation hearing.
According to
the comment letter filed with the DOL by Eugene Scalia, the late Supreme Court Justice Antonin Scalia's son, «Congress did not develop this provision in a vacuum, but drew from existing law.»
On October 3, 2017 the ICA filed
a comment letter with ICANN regarding the proposed revisions to the renewal Registry Agreement (RA) for the.
In
a comment letter responding to the proposed rule, the Chamber of Commerce and the International Franchise Association called it a «compliance nightmare.»
Sixty
comment letters were received, which will help us analyze the facts behind the concerns raised and in assessing whether there is a need for securities regulation intervention.»
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comment letters, research briefs, and testimony provided by DCIIA for individuals who want to stay informed on DC issues.