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DOL Again Applies Expansive Interpretation of "Subcontractor"

Client Alert | less than 1 min read | 10.29.10

In Office of Fed. Contract Compliance Programs v. Fla. Hosp. of Orlando (Oct. 28, 2010), a DOL Administrative Law Judge determined that a hospital providing medical services pursuant to an agreement with a TRICARE-managed care support contractor was a government subcontractor for purposes of a DOL audit of the hospital's compliance with its affirmative action and non-discrimination obligations. As discussed further in our blog, the ALJ analogized the hospital's status in this case to the hospital that provided medical services pursuant to an agreement with an FEHBP contractor in the UPMC Braddock case last year, which is currently under appeal.

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Client Alert | 11 min read | 12.15.25

New York LLC Transparency Act: Key Requirements and Deadlines

On January 1, 2026 (“Effective Date”), the New York LLC Transparency Act ("New York Act”) is scheduled to take effect, introducing new disclosure requirements for limited liability companies (“LLCs”) formed or registered to do business in New York State.  The New York Act is expected to impose the type of broad beneficial ownership requirements the federal CTA and rules implementing it was designed to require, before the federal government’s decision to limit the scope of the CTA’s beneficial ownership reporting requirements to foreign companies and foreign beneficial owners....