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,”…
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…
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The effective date of the Corporate Transparency Act and its corresponding rules promulgated by FinCEN was January 1, 2024. In January 2023, we published an article that discussed the intent and importance of the CTA (available here). The CTA may be a landmark piece of legislation that reshapes how certain entities report and disclose information…
We are pleased to announce today that Chambers USA ranked Milligan Lawless, P.C. and 4 of our attorneys among the best in Arizona for 2024. Among Arizona law firms, Milligan Lawless achieved a Band 1 ranking, Chambers USA’s highest recognition, in the Healthcare practice area. Chambers USA is an annual ranking that assesses each law…
The Eliminating Kickbacks in Recovery Act (“EKRA”) was enacted in 2018 in an effort to address fraud occurring in substance use disorder (“SUD”) treatment. EKRA prohibits paying, receiving, or soliciting remuneration in return for patient referrals to laboratories, recovery homes, and clinical treatment facilities.[1] Under EKRA, clinical treatment facilities are defined broadly to include, “a…
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