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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 | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....