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FTA Softens Blow of Stricter Buy America Requirements for Rolling Stock

Client Alert | 1 min read | 04.12.16

On April 6, 2016, the Federal Transit Administration proposed a policy statement and a public interest waiver, both clarifying that the increased U.S. content percentages mandated by the FAST Act will not apply to contracts entered into before the act’s October 1, 2015, effective date and waiving application of the higher percentages to any other contracts resulting from solicitations advertised prior to December 4, 2015 (the date the law was enacted). The FAST Act itself provided some relief from the increased percentages by requiring the FTA, when denying non-availability waivers, to certify to the identity of domestic suppliers of the iron, steel, or manufactured good at issue and by allowing inclusion of domestically sourced iron or steel used in foreign manufactured car shells or rolling stock frames to be included in the calculation of the domestic cost percentage.

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Client Alert | 7 min read | 05.27.26

Colorado Hits Reset on AI Regulation: SB 26-189 Repeals and Reenacts the Colorado AI Act

Colorado’s original AI Act (SB 24-205), signed in May 2024, imposed broad obligations on developers and deployers of “high-risk AI systems” — including requiring risk management programs, impact assessments, and affirmative steps to prevent algorithmic discrimination across employment, housing, lending, insurance, health care, and education decisions. The operative date for SB 24-205 was extended twice, and a court temporarily suspended enforcement in early 2026, following a lawsuit filed by xAI, which the U.S. Department of Justice (DOJ) intervened to support. Industry feedback on SB 24-205 was generally negative. In response to this environment, Colorado’s legislature undertook a rewrite, drafting and passing SB 26-189 in a matter of weeks. SB 26-189 reflects the legislature’s effort to preserve the policy goal of filling the AI oversight vacuum given the lack of a comprehensive federal law, but within a more workable compliance framework....

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