Are you Checking the PMP Before Prescribing? Pharmacy Board Audits of PMP Data

The Arizona Controlled Substances Prescription Monitoring Program (“PMP”) was established in 2007 and provides the State of Arizona with a central database to track the dispensing of controlled substances.  The PMP is designed to assist providers in making better-informed decisions and help “prevent the diversion and misuse of controlled substances at the provider, pharmacy, and…

NEW CORPORATE TRANSPARENCY ACT UPDATE: Fifth Circuit Court Vacates its Stay to the Preliminary Injunction Blocking Enforcement of the CTA

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated its prior December 23, 2024 decision to stay the December 3, 2024 preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.  As of the date of this notice and on…

CORPORATE TRANSPARENCY ACT UPDATE: Fifth Circuit Court Stays Preliminary Injunction Blocking Enforcement of the CTA; FinCEN Issues Updated Guidance

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit stayed the December 3, 2024 preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.  As of the date of this notice, the CTA has been reinstated nationwide.   In light of…

Preliminary Injunction Temporarily Blocks Enforcement of the Corporate Transparency Act Nationwide

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction, temporarily blocking enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.[1] For the time being, the preliminary injunction means reporting companies are not required to comply with the CTA’s reporting requirements…

Federal Trade Commission Adopts New “Click-to-Cancel” Rule

Written by: Ian M. Stanford and Steven T. Lawrence If your business includes any sort of subscription-based or membership model, a new federal regulation may change how your customers cancel their subscription or membership.  On October 16, 2024, the Federal Trade Commission announced its final “Click-to-Cancel” rule.  The new rule applies to “negative option programs,”…

The Corporate Transparency Act: July and September 2024 Update to the Beneficial Ownership Information Frequently Asked Questions

In July and September 2024, FinCEN provided some additional guidance on the Corporate Transparency Act (“CTA”) by updating its Frequently Asked Questions web page related to beneficial ownership information report filing obligations of terminated, administratively dissolved and disregarded entities, and clarifying the contents of such beneficial ownership information report filings.  Below is a brief summary…