The Small Business Runway Extension Act Is One Step Closer to Take Off
Client Alert | 1 min read | 07.08.19
On June 24, 2019, the U.S. Small Business Administration published a rule proposing to amend the time period for calculating average annual receipts for SBA’s receipts-based size standards from three to five years. This rule would implement the congressional intent behind the Small Business Runway Extension Act of 2018, which the SBA previously instructed did not permit small businesses to immediately begin certifying against a five-year time period. In the proposed rule, the SBA again warns that the three-year calculation period continues to apply to any offer submitted prior to the effective date of a final rule. Comments on the proposed rule are due by August 23, 2019.
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Client Alert | 3 min read | 02.11.26
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates.
Client Alert | 3 min read | 02.10.26
UK FCA Proposes New Sustainability Disclosure Rules for Listed Companies
Client Alert | 3 min read | 02.09.26
Client Alert | 1 min read | 02.09.26
Worried Three’s a Crowd? Decline Intervention at Your Own Peril



