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Our Tax group provides federal, state, and international tax advice to a wide variety of clients, from start-ups to multinational corporations at all stages of their life cycle. The lawyers in our group carefully guide clients through a myriad of complex tax rules and regulations and provide thoughtful and comprehensive solutions that help clients achieve their business objectives.

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We regularly help domestic and foreign corporations and partnerships, equity funds and investment bankers find creative solutions to address complex tax issues arising from transactions and general business operations. We also have a national Tax Controversy and Litigation group that represents individuals, businesses, governmental entities and nonprofit organizations in all phases of federal, state and international tax disputes.

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Insights

Client Alert

Treasury and IRS’s Proposed Regulations Would Significantly Alter Racial Nondiscrimination Requirements for Tax-Exempt Private Schools, Including Colleges and Universities

September 8, 2026

On September 4, 2026, the Department of Treasury (“Treasury”) and Internal Revenue Service (“IRS”) published proposed regulations under § 1.501(c)(3)-2(b) (the “Proposed Regulations”) that, if finalized, would significantly change the existing rules on the racial nondiscrimination requirements for tax-exempt private schools. This includes the approximately 18,000 primary and secondary schools, colleges, universities, professional schools, and trade schools in the United States that currently qualify for tax-exempt status as organizations described in Sections 501(c)(3) and 170(b)(1)(A)(ii) of the Internal Revenue Code of 1986, as amended (the “Code”). The Proposed Regulations adopt an absolute rule that a private school is not operated exclusively for exempt purposes if it adopts, maintains, or enforces any policy or practice that discriminates on the basis of race, color, or national or ethnic origin in administering any educational, admissions, scholarship or loan, athletic, or other school-administered or school-supported policy or program, clarifying that discrimination “for any purpose” is disqualifying. The stated basis for the rule change is that there is a fundamental public policy of the United States against racial discrimination in education, and that schools engaging in such discrimination are not eligible for section 501(c)(3) status. The preamble to the Proposed Regulations cites various antidiscrimination laws as well as U.S. Supreme Court cases such as Bob Jones University v. United States, 461 U.S. 574 (1983) and the more recently decided Students for Fair Admissions v. President and Fellows of Harvard College, 600 U.S. 181 (2023), as demonstrating this fundamental public policy. The Proposed Regulations would apply to tax-exempt private schools in taxable years beginning after May 31, 2027. Existing Nondiscrimination Requirements The IRS’s current racial nondiscrimination requirements for private schools are described in Revenue Procedure 75-50, 1975-2 C.B. 587, as modified by Revenue Procedure 2019-22, 2019-22 I.R.B. 1260 (“Rev. Proc. 75-50, as modified”). The Revenue Procedure establishes guidelines and recordkeeping requirements for private schools to ensure they have and operate under a “racially nondiscriminatory policy as to students.” Under Rev. Proc. 75-50, as modified, a “racially nondiscriminatory policy as to students” means: the school admits the students of any race to all the rights, privileges, programs, and activities generally accorded or made available to students at that school and that the school does not discriminate on the basis of race in administration of its educational policies, admissions policies, scholarship and loan programs, and athletic and other school-administered programs. Section 3.02 of Rev. Proc. 75-50, as modified, clarifies that “discrimination on the basis of race” includes discrimination on the basis of color and national or ethnic origin. In addition, if a school selects students on the basis of membership in a religious denomination or unit, the school will not be deemed to have a discriminatory policy as long as membership in the denomination or unit is open to all on a racially nondiscriminatory basis. Most notably, Rev. Proc. 75-50, as modified, allows favoring minority groups to promote nondiscrimination. The second sentence of section 3.02 provides: A policy of a school that favors racial minority groups with respect to admissions, facilities and programs, and financial assistance will not constitute discrimination on the basis of race when the purpose and effect is to promote the establishment and maintenance of that school’s racially nondiscriminatory policy as to students. To this end, the third sentence of section 4.05 of Rev. Proc. 75-50, as modified, states that scholarships and loans that are made pursuant to financial assistance programs favoring members of one or more racial minority groups that are designed to promote a school’s racially nondiscriminatory policy will not adversely affect the school’s exempt status. Similarly, the fourth sentence of section 4.05 provides that financial assistance programs favoring members of one or more racial groups will not adversely affect tax-exempt status if they do not significantly derogate from the school’s racially nondiscriminatory policy. The requirements under Rev. Proc. 75-50, as modified, are currently enforced by requiring existing tax-exempt private schools to maintain certain records and information showing compliance with the requirements and to annually certify compliance in Schedule E to IRS Form 990, Return of Organization Exempt From Income Tax. New tax-exempt private schools must demonstrate fulfillment of the requirements in Schedule B to IRS Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, to receive tax-exempt status. What’s Changed The key difference in the Proposed Regulations from the existing nondiscrimination requirements set forth in Rev. Proc. 75-50, as modified, is what actions count as “racial discrimination.” The Proposed Regulations contain an absolute rule that a private school is not operated exclusively for exempt purposes if it adopts, maintains, or enforces any policy or practice that discriminates on the basis of race, color, or national or ethnic origin in administering any educational, admissions, scholarship or loan, athletic, or other school-administered or school-supported policy or program, clarifying that discrimination “for any purpose” is disqualifying. According to the preamble, a disqualifying purpose includes race-based policies or programs with the intent to ameliorate the effects of past racial discrimination, a practice that is expressly permitted by Rev. Proc. 75-50, as modified. In addition, the Proposed Regulations would delete the allowances in Rev. Proc. 75-50, as modified, for minority-favoring policies and scholarships/loans by deleting the second sentence of section 3.02 and the third and fourth sentences of section 4.05 of Rev. Proc. 75-50, as modified, described above. Of note, the Proposed Regulations leave the exception for religious denomination intact, providing that selecting students based on religious affiliation or membership is not race discrimination if the criterion is based solely on religion and not on shared ancestry or ethnic characteristics. Further, the Proposed Regulations still permit private schools to consider characteristics such as first-generation status, individual hardship (demonstrated financial or personal struggle), family income, and geographic location. Finally, similar to Rev. Proc. 75-50, as modified, the Proposed Regulations apply to schools as described in Section 170(b)(1)(A)(ii) of the Code and not those exempt as a governmental unit or under Code Section 509(a)(2). If finalized, the standard set forth in the Proposed Regulations is intended to bind tax-exempt private schools effective for tax years after May 31, 2027. This means schools’ tax-exempt status, including eligibility for tax-exempt bonds, could be impacted as early as fiscal year 2028. What’s Still Unclear The Proposed Regulations leave many unanswered questions for tax-exempt private schools. Eliminating Prejudice and Discrimination Standard The preamble to the Proposed Regulations indicates that tax-exempt private schools may continue to take actions or adopt policies intended to eliminate prejudice and discrimination; provided that the organization achieves these purposes by means other than actions or policies that discriminate on the basis of race, color, or national or ethnic origin. This is an important carveout, since the definition of “charitable” for purposes of section 501(c)(3) of the Code includes eliminating prejudice and discrimination. See Treas. Reg. 1.501(c)(3)-1(d)(2)(ii). What’s unclear under the Proposed Regulations, however, is how the elimination of prejudice and discrimination may be accomplished by private schools given that decades of IRS rulings expressly permit practices that are now considered contrary to the Proposed Regulations. Revising Eligibility Criteria The preamble to the Proposed Regulations acknowledges that private schools may revise eligibility criteria for scholarships and loans to conform to the Proposed Regulations, including using geographic or income-based criteria in lieu of racial or ethnic criteria to accomplish substantially similar outcomes. It generally minimizes, however, the compliance costs and impacts making these changes would have on private schools, stating the Treasury Department and the IRS do not have “readily available parameters or models” to assess these things. It is therefore unclear how far private schools must go under the Proposed Regulations to revise eligibility criteria of existing programs to be considered in overall compliance with the requirements and whether there could be circumstances where the IRS would consider such changes a proxy for race-based determinations. There is also virtually no acknowledgement of the competing donor considerations in making such changes. Such considerations include, but are not limited to, laws regarding respecting donor intent such as the Uniform Prudent Management of Institutional Funds Act (UPMIFA), and donor free-speech rights under the First Amendment. State Law The preamble states that the Proposed Regulations do not have federalism implications, do not impose substantial direct compliance costs on State and local governments, and do not preempt State law within the meaning of Executive Order 13132. Nowhere in the document, however, do the Treasury Department and the IRS acknowledge that States may have antidiscrimination laws for private schools that are contrary to the Proposed Regulations or that State laws could impact the ability of private schools to revise eligibility criteria in the manner suggested by the preamble. Fundamental Public Policy The stated basis for the rule change is that there is a fundamental public policy of the United States against racial discrimination in education, and that schools engaging in such discrimination are not eligible for section 501(c)(3) status. The fundamental public policy standard stems from the U.S. Supreme Court’s decision in Bob Jones University v. United States, 461 U.S. 574 (1983) where the Court upheld the IRS’s revocation of tax-exempt status for schools that maintained racially discriminatory policies promoting racial segregation based on a fundamental public policy in the United States against such practices. Citing Students for Fair Admissions v. President and Fellows of Harvard College, 600 U.S. 181 (2023), the preamble to the Proposed Regulations states that all forms of racial discrimination in education, regardless of intent, are now against a fundamental public policy of the United States and preclude tax exemption. The question is whether the Treasury Department and the IRS have the authority to announce, through these Proposed Regulations, what a fundamental public policy of the United States is, and then use that fundamental public policy standard to make decisions on tax-exempt status. The fundamental public policy standard does not appear in Section 501(c)(3) of the Code and goes beyond the Bob Jones University decision involving the practice of racial segregation. The use of this standard to deny tax-exempt status also potentially raises First Amendment concerns, a discussion of which is beyond the scope of this update. Enforcement Neither the Proposed Regulations, nor the preamble to the Proposed Regulations address how the IRS intends to enforce the requirements under the Proposed Regulations. Presumably, tax-exempt private schools would continue to be required to show compliance on IRS Form 1023 and Schedule E to Form 990. The IRS also could create an audit initiative or campaign to address the new requirements. Given the procedural safeguards built into the Code, any such audits could take years to play out. What’s Next A number of groups have already publicly announced they intend to challenge the Proposed Regulations on a variety of grounds, such as statutory authority, administrative law, and constitutional claims. It is also possible that Congress could take action in this area. In the meantime, tax-exempt private schools should review existing policies and programs to determine whether any changes would be needed to comply with the Proposed Regulations. This could include review of educational program criteria and policies, admissions criteria and policies, scholarship or loan-related agreements and application documents, donor and gift agreements, athletic programs and policies, website information, and existing records to show compliance with racial nondiscrimination requirements. Schools should also continue to monitor the status of the Proposed Regulations and potential challenges, any changes to IRS forms related to reporting compliance with the nondiscrimination requirements, and any IRS audit initiatives for private schools. The Treasury Department and the IRS have asked for comments on all aspects of the Proposed Regulations. All comments should be submitted in writing, either electronically or by paper, to the Treasury Department and the IRS by November 3, 2026, following the procedures provided in the notice. For schools that wish to submit comments or that have questions or need assistance regarding the Proposed Regulations, please contact Katrina Wessbecker or Claire Topp from Dorsey’s Nonprofit and Tax-Exempt Organizations practice group.

Client Alert

Treasury and the IRS Give Guidance on "Material Assistance" Rules

March 6, 2026

On February 12, 2026, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released IRS Notice 2026-15 (the “Notice”), which provides guidance on the “material assistance” rules enacted as part of the One Big Beautiful Bill Act (the “OBBBA”). Among other things, the OBBBA introduced a series of restrictions that disallow certain tax credits otherwise available under Sections 45Y, 48E, 45X, 45Z, 45U, and 45Q of the Internal Revenue Code (the “Code”) where a “prohibited foreign entity” (each, a “PFE”) is involved. Like credits under Sections 45Z, 45U, and 45Q that face strict entity-level disqualifications if the taxpayer is a PFE, credits under Sections 45X, 45Y, and 48E face the same strict entity-level ban, as well as an additional “material assistance” restriction. This restriction disallows tax credits if the taxpayer receives material assistance from PFEs, meaning that the “material assistance cost ratio” (“MACR”) is below certain specified threshold percentages, which vary by product and over time. This Notice is the first formal guidance on the PFE-related rules but is limited to the narrow issue of “material assistance” applicable only to Sections 45X, 45Y, and 48E by (a) explaining how to calculate MACR and (b) clarifying the use of three “interim safe harbors”. A. MACR Calculation Section 3 of the Notice outlines a four-step framework for calculating MACR. As a general matter, taxpayers are required to calculate a separate MACR for each qualified facility and each energy storage technology (“EST”) it operates, or for each eligible component it manufactures. Step 1: Identify the types of manufactured products (“MPs”) and manufactured product components (“MPCs”) included in qualified facilities and ESTs, or the types of constituent elements, materials, or subcomponents (“Constituent Materials”) incorporated in the production of eligible components.1 Step 2: Track (a) the “Direct Costs” of each MP or MPC, or the “Direct Material Costs” of each Constituent Material, and (b) whether each MP, MPC, or Constituent Material is mined, produced or manufactured by PFEs (“PFE-Produced/Sourced”). Unless relying on certain exceptions, taxpayers are required to track each MP, MPC, and Constituent Material on an individual basis. a. De Minimis Exception: This exception permits taxpayers to assign MPs or MPCs of the same type among multiple qualified facilities or ESTs placed in service during the same taxable year, if the Direct Costs of all MPs and MPCs represent less than 10% of the total Direct Costs of each qualified facility or EST. b. Averaging Exception: This exception permits taxpayers to (a) track the average Direct Cost/Direct Material Cost of MPs, MPCs, or Constituent Materials of the same type, and (b) determine whether an MP, MPC, or Constituent Material is PFE-Produced/Sourced by calculating the percentage of such items of the same type that are PFE-Produced/Sourced across qualified ESTs or eligible components produced during specified time periods. The “averaging exception” further suggests that a taxpayer may divide a taxable year into multiple “specified periods” and calculate a separate MACR for each period. c. Binding Contract Exception: The Notice confirms a critical statutory grandfathering rule under Section 7701(a)(52)(D)(iv) of the Code. Upon a taxpayer’s election, the cost of any MP, MPC or Constituent Material, acquired pursuant to a binding written contract entered into prior to June 16, 2025, is entirely excluded from the MACR calculation. Nonetheless, this exclusion is subject to specific timing requirements, including construction commencement and place-in-service deadlines for qualified facilities, and sale deadline for eligible components. Step 3: Determine the “Direct Costs” of all MPs incorporated into the qualified facility or EST, or the “Direct Material Costs” of all Constituent Materials used in the production of the eligible component. a. “Direct Costs” of MPs for Qualified Facilities and ESTs: If a taxpayer purchases an MP, the Direct Costs of such MP are simply its acquisition costs (excluding purchaser’s labor costs). In contrast, if a taxpayer manufactures any MP or MPC itself, then the Direct Costs should consist of both the direct material costs and the direct labor costs. b. “Direct Material Costs” of Constituent Materials for Eligible Components2: These are costs that a taxpayer paid or incurred for materials that become an integral part of the eligible component and/or that are consumed in the ordinary course of producing the eligible components. Under this principle, Treasury and the IRS take the position that freight-in costs and tariffs should be included in the calculation of Direct Material Costs. In addition, the Notice provides guidance on calculating Direct Material Costs in the contract manufacturing context. Step 4: Determine the “PFE Direct Costs” of all MPs incorporated into the qualified facility or EST (which should include the cost of all MPCs in each MP), and the “PFE Direct Material Costs” of all Constituent Materials used in the production of the eligible component. The Notice clarifies that whether an MP, MPC or Constituent Material is PFE-Produced/Sourced depends on the PFE status of the supplier as of the taxable year during which the taxpayer paid the Direct Costs/Direct Material Costs of such MP, MPC or Constituent Material. a. “PFE Direct Costs” of MPs for Qualified Facilities or ESTs: The Notice provides specific guidance on how to calculate “PFE Direct Costs” when an MP includes both PFE-Produced/Sourced and non-PFE-Produced/Sourced MPCs. b. “PFE Direct Material Costs” of Constituent Materials (for Eligible Components): The Notice clarifies that, if the direct supplier of a Constituent Material is merely a reseller, then the taxpayer should apply the definition of “PFE” (as defined in Section 7701(a)(51) of the Code) to the entity that actually mined, produced, or manufactured the Constituent Material for all costs associated with those Constituent Materials. This clarification may be read to suggest that the use of a non-PFE to resell PFE-Produced/Sourced Constituent Materials cannot circumvent the material assistance rules. B. Interim Safe Harbors The OBBBA and the Notice provide for several “interim safe harbors” which make the MACR calculation less onerous for taxpayers. a. Identification Safe Harbor and Cost Percentage Safe Harbor The Identification Safe Harbor: It allows taxpayers to use the “2023 - 2025 Safe Harbor Tables”3 to identify MPs and MPCs of a qualified facility or EST, or Constituent Materials of an eligible component. The Cost Percentage Safe Harbor: It allows taxpayers relying on the Identification Safe Harbor to apply a prescribed cost percentage to each MP, MPC and Constituent Material for the calculation of Direct Costs/Direct Material Costs, PFE Direct Costs/PFE Direct Material Costs, and MACR. The Notice imposes certain limitations on taxpayers’ eligibility to use the Identification Safe Harbor and the Cost Percentage Safe Harbor. A taxpayer operating a qualified facility or EST may use these two safe harbors only if such qualified facility or EST is listed as an “Applicable Project” in the 2023-2025 Safe Harbor Tables. A taxpayer manufacturing an eligible component may use these two safe harbors only if such eligible component is listed in Section 4.01(3)(d) of the Notice. To the extent that a taxpayer is eligible to use the Identification Safe Harbor and the Cost Percentage Safe Harbor, it may identify the relevant MPs, MPCs and Constituent Materials (as well as their respective cost percentage) by table reference and disregard any items used in actual production that are not listed in the applicable 2023-2025 Safe Harbor Table. In addition, if the applicable table lists any MP, MPC or Constituent Material that is not used in actual production, such item could also be disregarded for purpose of calculating MACR. b. Certification Safe Harbor The Certification Safe Harbor allows taxpayers to determine whether an MP, MPC or Constituent Material is PFE-Produced/Sourced so that taxpayers do not need to independently conduct an exhaustive supply-chain analysis. In addition to certain formality requirements (including providing the supplier’s EIN and signing under penalties of perjury), a valid certification from a direct supplier should be structured as a written attestation that includes one of the following: Option A: The supplier may provide a broad certification that the MP, MPC, eligible component or Constituent Material (as applicable) it supplied was not PFE-Produced/Sourced, and that it does not know (or have reason to know) that any prior supplier in the chain of production is a PFE; or Option B: Instead of providing the broad certification described in Option A, the supplier may alternatively certify the total Direct Costs/Direct Material Costs of the non-PFE-Produced/Sourced MP, MPC, eligible component or Constituent Material (as applicable). However, taxpayers and suppliers should be aware that the abusive use of this safe harbor may result in penalties and could expose them to significant financial and legal risks.  C. What Happens Next? a. Rules that Treasury and the IRS Expect to Include in Future and Present Clarifications Treasury and the IRS indicate that they will include comprehensive rules in forthcoming regulations regarding the “Application of foreign-influence entity rules.” However, Section 5.01 of the Notice already provides an immediate, critical guidance on “effective control.” The Notice states that the statutory control provisions operate independently. For example, if a taxpayer makes a payment to a Specified Foreign Entity (each, an “SFE”) under an IP licensing agreement related to a facility or eligible component, and that agreement was entered into or modified on or after July 4, 2025, the SFE exercises effective control, automatically rendering the taxpayer a Foreign-Influenced Entity. Further forthcoming regulations will include rules to “prevent entities from evading, circumventing, or abusing the application of the PFE restrictions”, which may further clarify the scope of the OBBBA’s anti-circumvention provisions. b. Comment Period and Process Taxpayers are encouraged to submit comments to Treasury and the IRS on general issues relating to PFE and material assistance, as well as on certain specific questions set forth in Section 7.01 of the Notice, by March 30, 2026. c. Reliance on the Notice Taxpayers may rely on Sections 3 and 5.01 of the Notice until the date that is 60 days after the publication of the forthcoming regulations and may rely on Section 4 of the Notice until the date that is 60 days after the publication of the forthcoming safe harbor tables. Dorsey & Whitney can continue to monitor developments and provide updates and analysis regarding this Notice and forthcoming regulations addressing PFE issues. 1 “MP” is defined in Section 3.01(2)(c) of Notice 2023-38, “MPC” is defined in Section 3.01(2)(d) of Notice 2023-38, and certain additional definitions could be found in Section 3.01(2) of Notice 2023-38. 2 Taxpayers relying on Section 45X integrated components rule should be aware of new statutory limitations. 3 “2023-2025 Safe Harbor Tables” include: (a) Sections 5.05, 5.06, 6.02, and 7.02 of Notice 2025-08, (b) Section 3.02 in Notice 2024-41 for a Hydropower Facility or a Pumped Hydropower Storage Facility, and (c) Section 3.04 in Notice 2023-38 for an Offshore Wind Facility. The guidance contained in IRS Notice 2026-15 is interim in nature and precedes the issuance of comprehensive proposed regulations by the Department of the Treasury. Consequently, the interpretation and enforcement of the OBBBA are rapidly evolving. This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their specific facts and circumstances, particularly regarding the complex supply chain and ownership restrictions imposed by the OBBBA. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer. The information contained herein is general in nature and based on authorities that are subject to change without notice.

Firm Highlights

Insights

Observations on the SEC’s 2027 Examination Priorities

The SEC’s Division of Examinations (the “Division”) recently announced its examination priorities (“Exam Priorities”) for fiscal year 2027.1 Although many of the Division’s core areas of focus remain consistent with fiscal year 2026, the 2027 Exam Priorities include notable changes and refinements, which we discuss below, along with other key 2027 examination priorities. Dorsey Observations Renewed focus on economic conflicts of interest. After certain economic-incentive topics received less emphasis in the 2026 Exam Priorities2, the Division has again expressly identified economic conflicts as an examination focus. The 2027 Exam Priorities indicate that the Division will prioritize reviewing advisers’ fiduciary obligations relating to economic conflicts of interest raised by fee rebates, fee and expense calculations, cash management, quid pro quo arrangements, and deposits and withdrawals. Greater emphasis on private-fund practices. Building on the private-fund items in the 2026 Exam Priorities, the 2027 Exam Priorities indicate that the Division will assess private-fund disclosures and controls relating to investment allocations, leverage, affiliated service providers, and fees and expenses. The Division also identified investments in private companies through special purpose vehicles (“SPVs”) and loans provided by private funds and business development companies (“BDCs”) as products the Division will scrutinize. Advisers, particularly private-fund advisers, should evaluate whether their disclosures and compliance programs address these areas. Expanded focus on AI-related cybersecurity risks. While the 2026 Exam Priorities focused on advisers’ use of and representations regarding artificial intelligence (“AI”), the 2027 Exam Priorities specifically highlight AI-enabled cybersecurity threats, including AI-generated phishing and synthetic or “deepfake” voice and video used for social engineering. The shift signals that registrants should consider whether their cybersecurity policies and controls adequately address these evolving threats. New focus on proxy advisory firms. The 2027 Exam Priorities state that the Division will examine advisers that rely on proxy advisory firms, including how those advisers evaluate the firms’ recommendations, assess the bases for those recommendations, identify potential conflicts of interest, and determine whether that reliance satisfies applicable legal obligations. Advisers that rely on proxy advisory firms may wish to consider whether their compliance programs address these areas. Updated focus on Regulation S-P and Regulation S-ID. The 2026 Exam Priorities stated that the Division would engage firms during examinations regarding their progress in preparing incident response programs ahead of the compliance dates for the amendments to Regulation S-P and would examine compliance with the amended rule after those dates. The 2027 Exam Priorities indicate that examinations will focus on whether firms have developed, implemented, and maintained reasonably designed policies and procedures addressing administrative, technical, and physical safeguards to protect customer information and that, in accordance with the amended rule, staff will evaluate response program policies and procedures for unauthorized access to or use of customer information, including customer notification procedures and oversight of service providers. With respect to Regulation S-ID, the 2027 Exam Priorities indicate that examiners will assess whether firms are updating their Identity Theft Prevention Program to address emerging risks, such as those related to AI and stolen credentials. Advisers may wish to consider whether their compliance programs address these areas, as applicable. Summary of Other 2027 Examination Priorities Beyond the developments discussed above, many of the Division’s core examination priorities remain consistent with fiscal year 2026. These include investment adviser fiduciary obligations and compliance programs, examinations of never-examined and recently registered advisers, and cybersecurity and operational resiliency. The Exam Priorities are not exhaustive, and examinations will vary based on each registrant’s business, activities and risks. Advisers should consider the 2027 Exam Priorities in reviewing their compliance programs and preparing for potential examinations, including by: Reviewing risk disclosures and controls. The Division states that, when examining advisers to private funds, it will assess whether investment-related risk disclosures are consistent with fiduciary standards and whether compliance policies, procedures, and controls are designed to address both fund-level and investment-level risks. Reviewing disclosures on allocations, leverage, and affiliated service providers. The 2027 Exam Priorities identify disclosures related to certain investments and allocations, the use of debt and fund-level lines of credit, and the use of affiliated service providers as examples. Confirming the accuracy of fee and expense calculations. The Division states that it will assess the accuracy of fee and expense calculations at both the fund and investment levels, and it identifies fee rebates, cash management, quid pro quo arrangements, deposits, and withdrawals as areas in which economic conflicts of interest may affect the impartiality of advice. Reviewing recommendations of illiquid or hard-to-trade products. The Division states that it will prioritize advisers that recommend products that are difficult to trade, have unusual features, or are illiquid, including loans provided by private funds or BDCs and investments in private companies through SPVs. Confirming that the compliance program is implemented and reviewed. The Division states that it will review compliance program components such as marketing, valuation, and custody, as appropriate, and will typically analyze the annual compliance review. It will also focus on compliance practices when advisers have started advising new asset classes or clients or grown through mergers or acquisitions. 1 SEC Division of Examinations 2027 Examination Priorities. 2 See Dorsey’s Client Alert on the SEC’s fiscal year 2026 exam priorities.

Insights

Minnesota Consumer-Fraud Enforcement: Disclaimers Won’t Cure Deception, and Penalties Can Add Up

Misleading advertising claims can lead to costly consequences. In State of Minnesota ex rel. Ellison v. Wall & Associates, Inc., No. A25-2064, 2026 WL 3118291 (Minn. App. Oct. 19, 2026), the Minnesota Court of Appeals recently affirmed a bench trial verdict against a tax-relief company and two executives for violations of the Minnesota Consumer Fraud Act (“MCFA”) and the Minnesota Deceptive Trade Practices Act (“MDTPA”). The decision, which affirmed a substantial restitution and civil penalty judgment, underscores the broad power of the Minnesota Attorney General to act against deceptive sales practices. The decision also offers practical lessons for businesses seeking to reduce liability risks in consumer-facing communications. Background Wall & Associates (“W&A”), a Virginia-based tax-relief company, marketed assistance to taxpayers seeking relief from outstanding federal and state tax liabilities, often with offers in compromise—agreements to settle tax liabilities for less than the amount owed. In its extensive advertising campaigns, W&A represented that its average client received a 90% reduction in their tax debt, that it was a local company with Minnesota offices, that it provided legal services, and that it would “Solve ALL Tax Problems.” In reality, W&A’s promises bore little resemblance to what many clients received. Most of W&A’s clients saw just a 9.5% reduction in federal tax debt and 1.2% in state tax debt. W&A had no permanent Minnesota offices. And W&A provided neither legal representation nor assistance with filing tax returns—those services required referrals to separate firms for an additional fee. All the while, W&A clients paid upfront and recurring fees, including during periods when W&A did no work on their cases. Minnesota Attorney General Keith Ellison sued W&A, its founder and owner Ernest Kenneth Wall, and its president and CEO Patrick Mark Yates, alleging violations of, among other laws, the MCFA and the MDTPA. Following a 12-day bench trial, the district court determined that W&A violated the MCFA and MDTPA through its false and embellished advertising. The district court also held Wall and Yates individually liable for those violations because they directed, participated in, and acquiesced in the violations. The district court ordered injunctive relief, $2.7 million in restitution (with Wall and Yates jointly and severally liable for $1.3 million), and civil penalties of $786,517 against W&A, $415,500 against Wall, and $207,750 against Yates. The district court also awarded over $2.5 million in attorneys’ fees and costs to the state. W&A, Wall, and Yates appealed to the Minnesota Court of Appeals, which affirmed the district court’s decision on October 19, 2026. Although W&A, Wall, and Yates challenged the judgment on numerous grounds, several highlights of the decision provide important takeaways for consumer-facing businesses. Individual Reliance Is Not Required for Statutory Liability W&A argued that Attorney General Ellison had to prove a causal nexus between each violation of the MCFA and MDTPA and the injury to a particular consumer to establish liability. In W&A’s view, this required proof that each injured consumer had personally relied on W&A’s false representation. The Court of Appeals rejected this argument based on the MCFA’s and MDTPA’s plain language, which requires no proof of actual deception or confusion by consumers. The Court of Appeals finally pointed to the Minnesota Supreme Court’s decision in State v. Minnesota School of Business, Inc., which held that when a defendant’s misrepresentations are directed at and affected “a broad group of consumers, proof of direct individual reliance is not required to establish a causal nexus between MCFA violations and the harm suffered by consumers.” 935 N.W.2d 124, 135 (Minn. 2019). The Court of Appeals affirmed, however, that a causal nexus is necessary to support an award of damages under the MCFA and MDTPA. In making that determination, district courts look to various factors, including whether the misrepresentations were “longstanding, pervasive, and widespread in communications directed to consumers,” whether the seller intended and understood that consumers would rely on the misrepresentations, and whether the information was of a kind on which consumers would typically rely. The Court of Appeals’ decision continues Minnesota School of Business’s broad interpretation of liability under the MCFA and the MDTPA. Coordinated marketing campaigns to a “broad group of consumers” may expose businesses to MCFA and MDTPA liability without customer-by-customer proof of injury. That said, a causal nexus remains an element of an MCFA and MDTPA claim, and businesses involved in litigation should build a clear record at trial and on appeal showing how each of the relevant factors bears on the causal-nexus inquiry. Contractual Disclaimers Are Not an Automatic Defense to a Misleading Pitch W&A next argued that disclaimers in its client contracts prevented consumers from claiming they had been misled by its advertising. Reiterating that individual reliance is not required under the MCFA and MDTPA, the Court of Appeals held that a contractual disclaimer does not necessarily defeat a claim based on a conflicting oral representation. And on the facts of this case, the Court of Appeals agreed with the district court that W&A’s contractual disclaimers were insufficient given the extensive misrepresentations by W&A and the unequal bargaining power between it and its customers. This holding confirms that contractual disclaimers are not a cure-all for misleading advertising or sales practices. Businesses should review the entire customer journey, including pre-contract representations, as those representations may survive a contractual disclaimer to the contrary. And if faced with litigation, businesses should build a strong record, both at trial and on appeal, showing why any disclaimer is effective in context. The State Has Broad Authority to Seek Restitution W&A also challenged Attorney General Ellison’s authority to seek restitution under the state’s parens patriae authority to protect residents’ collective interests, arguing that injury to only 228 Minnesotans did not affect a sufficiently substantial segment of the population. The Court of Appeals rejected a simple headcount approach, instead explaining that the state had a legitimate interest in protecting residents’ economic well-being as a whole. In any event, the Court of Appeals held that if restitution was not appropriate under the state’s parens patriae authority, then it would still be appropriate under the Attorney General’s enforcement powers under Minn. Stat. § 8.31. The decision reinforces that the broader and more sustained the deceptive advertising, the stronger the case for restitution to protect Minnesotans’ economic interests. Civil Penalties Accrue Per Violation, Not Per Defendant The Court of Appeals finally rejected W&A’s claim that the Attorney General’s enforcement powers under Minn. Stat. § 8.31 permit only civil penalties of up to $25,000 for each defendant. Rather, the Court of Appeals explained that penalties are limited to $25,000 per violation. Multiple violations can therefore produce substantially greater penalties. The Court of Appeals also rejected the argument that restitution made penalties unnecessary: repaying consumers does not eliminate the need to address gains from deceptive conduct and deter future violations. Final Takeaways Align every consumer-facing communication. Broad and extensive marketing campaigns can expose businesses to stronger enforcement standards under the MCFA and MDTPA, making it critical that consumer communications remain accurate and consistent from the first advertisement through the final sale. Plan for layered enforcement exposure. Penalties under the MCFA and MDTPA can add up quickly: W&A, Wall, and Yates ultimately faced more than $6 million in civil penalties, restitution, and attorneys’ fees. The decision continues a line of Minnesota cases recognizing the Attorney General’s broad consumer-protection authority. Details matter. Although the Attorney General’s enforcement power is broad, it is not boundless. As the Court of Appeals explained, issues of causation, the effectiveness of contractual disclaimers, and the availability of restitution and civil penalties all turn on the specific facts of the case. Effective advocacy at trial and on appeal is critical to developing the facts relevant to liability and damages.

News

Dorsey & Whitney Advises Beijing Xunzhong on Two Consecutive H Share Placings Raising HK$418.5 Million

International law firm Dorsey & Whitney LLP acted as Hong Kong legal advisors to Beijing Xunzhong Communication Technology Co., Ltd. (“Xunzhong”) as to Hong Kong law in connection with two consecutive placings of new H shares under general mandate (the “First Placing” and the “Second Placing”, respectively, and together, the “Placings”). Xunzhong’s H shares are listed on the Main Board of the Hong Kong Stock Exchange (Stock Code: 2597). Winbull Securities International (Hong Kong) Limited acted as sole overall coordinator and placing agent on both Placings. The First Placing of 11,190,000 new H shares at HK$28.20 each was completed on September 17, 2026, followed by the Second Placing of 3,550,000 new H shares at HK$29.00 each on October 30, 2026. The Placings raised approximately HK$315.56 million and HK$102.95 million in gross proceeds, respectively, or approximately HK$418.51 million in aggregate (approximately HK$415.96 million in aggregate net proceeds). Both Placings were conducted under the same general mandate granted by shareholders at Xunzhong’s 2025 annual general meeting, and each was completed within one week of the signing of its placing agreement. Completing placings in consecutive months is relatively uncommon in the Hong Kong market, and doing so called on the technical depth of Dorsey’s Hong Kong Capital Markets team. Working closely with Xunzhong to understand its business needs and prepare the transaction documents, the team addressed in quick succession the remaining capacity under the general mandate, disclosure of the use of proceeds and the maintenance of Xunzhong’s public float, enabling both Placings to be completed seamlessly. “We are pleased to have advised Xunzhong on both Placings,” said Rachel Han, Partner and Co-Head of Dorsey’s Asia Capital Markets practice. “We appreciate the trust placed in our team and the close collaboration among all parties involved. We look forward to supporting Xunzhong as it continues to execute its growth strategy and pursue future capital markets opportunities.” Xunzhong is principally engaged in cloud-based communications services and enterprise digitalization services in the PRC. As disclosed in its announcements, the net proceeds of the First Placing are allocated to developing Xunzhong’s new computing power operation services business, while those of the Second Placing will be used to integrate model-as-a-service (MaaS) and AI agent capabilities into its existing cloud communications platform-as-a-service (PaaS) platform and software-as-a-service (SaaS) products. Approximately 55% of the net proceeds of the Second Placing will be used for computing power equipment upgrades for the MaaS system, approximately 35% for MaaS, PaaS and SaaS platform upgrades, and approximately 10% for working capital and general corporate purposes. With a single MaaS platform and shared computing power supporting its PaaS and SaaS offerings, Xunzhong intends for its MaaS, PaaS and SaaS capabilities to complement and reinforce one another, and to address customer needs from multiple angles, from embedding AI in customer communications and business workflows to maintaining stable performance at scale and keeping customer data within controlled environments. Partner and Co-Head of Dorsey’s Asia Capital Markets practice Rachel Han and Of Counsel in the Capital Markets and Corporate Compliance group Carlton Ng, along with Associate Kristy Ting, led the Dorsey Hong Kong Capital Markets & Corporate Compliance group in advising Xunzhong on both Placings.

Insights

The Methane Regulatory Pendulum Swings Again: EPA Proposes Sweeping Changes to Federal Standards for the Oil and Natural Gas Sector

Few environmental regulations better illustrate Washington’s regulatory “ping-pong” than EPA’s methane standards for the oil and natural gas sector. Over the last decade, successive administrations have repeatedly expanded, narrowed, rescinded, reinstated, and revised federal methane requirements, leaving industry to navigate a shifting compliance landscape with each change in administration. EPA’s October 27, 2026 proposal to reconsider significant portions of the 2024 oil and natural gas New Source Performance Standards (“NSPS”) and Emission Guidelines (“EG”) under Subparts OOOOb and OOOOc represents the latest swing of the regulatory pendulum. If finalized, the proposal would substantially reduce compliance obligations in several areas, particularly with respect to lower-producing wells, associated gas flaring, equipment and control-device standards, and the Super Emitter Program. EPA estimates that the proposal would result in approximately $45 billion in savings, while preserving what the agency considers appropriate methane emission controls. EPA’s proposal was published in the Federal Register on October 29, 2026. Comments must be received on or before December 16, 2026.  Significantly, EPA is not using this rulemaking to reconsider its general authority to regulate methane emissions from the oil and natural gas sector. Rather, the agency is addressing specific requirements adopted in the 2024 methane rule, while broader questions concerning greenhouse gas regulation are being addressed in separate proceedings. The present proposal therefore focuses on the appropriate design and scope of particular methane regulations, rather than resolving the threshold question of whether methane may be regulated under the Clean Air Act at all. I.    EPA Proposes to Eliminate the Super Emitter Program Among the proposal’s most consequential changes is the complete elimination of the Super Emitter Program. Adopted in 2024, the program created a regulatory framework under which EPA-certified third parties could identify large methane releases using approved remote-sensing technologies. Upon receiving a qualifying notification from EPA, owners and operators were required to investigate the reported emissions event, report findings to EPA, and take corrective action where necessary. EPA now proposes to repeal the Super Emitter Program in its entirety. The agency questions the program’s legal and policy foundations, including the role of third parties in identifying emissions events and triggering regulatory obligations. EPA also questions whether the program is necessary or effective given other requirements applicable to regulated sources and whether its expected emissions reductions justify its costs and implementation challenges. Because the program was incorporated into both the NSPS applicable to new, modified, and reconstructed sources and the EG applicable to existing sources, its removal would affect federal requirements as well as the presumptive requirements that States otherwise would be expected to address in Clean Air Act § 111(d) plans. Importantly, EPA’s proposed repeal does not prevent States from developing and implementing their own Super Emitter Program based on the existing requirements, which several states are already doing.  II.    EPA Reconsiders Associated Gas Requirements Another centerpiece of EPA’s proposal is its reconsideration of the 2024 rule’s restrictions on flaring associated gas from oil wells. The 2024 rule determined that the best system of emission reduction (“BSER”) generally required operators to capture and beneficially use associated gas by routing it to a sales line, using it onsite, or reinjecting it, rather than routinely flaring it. Although EPA provided certain transition periods and compliance flexibilities, particularly for wells facing infrastructure constraints, the rule ultimately established a framework strongly favoring capture and utilization over flaring. Since promulgation, EPA has received significant feedback regarding gathering-system limitations, gas quality issues, and other practical barriers operators face in securing outlets for associated gas. In response, EPA proposes to replace the existing capture-focused approach with a substantially more flexible standard. EPA argues that the 2024 rule relied too heavily on the availability of third-party gathering and processing infrastructure that is often beyond an operator’s control, raising questions regarding achievability and cost-effectiveness. Under the proposal, BSER would be based on routing associated gas to a flare or other control device capable of achieving at least a 95 percent reduction in methane and volatile organic compound (“VOC”) emissions. Operators could continue to capture gas for sale, use it onsite, or reinject it where feasible, but those practices would no longer be required. EPA also proposes that if a portion of associated gas is routed to sales or used for another purpose, the remaining portion must comply with the 95 percent standard. For example, if a company can route 40 percent of its associated gas to a sales line, the company would need to route the other 60 percent to a control device with a 95 percent reduction, or to a flare. EPA is also soliciting comment on less sweeping alternatives that would preserve the basic structure of the 2024 associated-gas program, while providing additional compliance flexibility. In particular, EPA requests comment on whether it should retain the current capture-and-sales framework but expand the circumstances under which temporary flaring is permitted or extend the duration of temporary flaring allowances where operators face infrastructure constraints. EPA appears to recognize that gathering-system availability, processing constraints, and other third-party factors can affect an operator's ability to route gas to sales, even where the operator ultimately intends to comply with the capture requirements. These requests for comment suggest that EPA is considering whether targeted revisions to the existing framework could address implementation concerns without fully abandoning the 2024 rule's underlying preference for gas capture and beneficial use. III.    EPA’s Reconsideration of the “No Identifiable Emissions” Standard EPA's proposal would substantially revise the 2024 rule’s “no identifiable emissions” (“NIE”) requirements applicable to certain covers and closed vent systems (“CVS”) associated with storage tanks. Under the existing rule, covered equipment generally must operate without identifiable emissions, creating a compliance framework that focuses heavily on the absence of observable emissions rather than solely on equipment design or overall control effectiveness. Since promulgation, industry has argued that the standard effectively functions as a zero-emissions requirement that may be difficult to satisfy under all operating conditions, even where equipment and vapor control systems are properly designed, maintained, and operated. Moreover, EPA stated in the preamble to the 2024 rule that any identified emissions would constitute a deviation of the emissions limitation, resulting in a framework under which the observation of emissions could itself establish noncompliance. EPA now proposes to separate the requirements into distinct design and operational components and to fundamentally alter how compliance with the operational NIE requirement is evaluated. EPA proposes to distinguish between deviations of the design requirements and deviations of the operational NIE requirements. Under the proposed approach, failure to repair an identified emission or defect within 24 hours would constitute a deviation of the design requirement, although not necessarily an underlying violation. Separately, operators could demonstrate compliance with the operational NIE requirement by making repairs as soon as practicable, with an initial repair attempt within five days and final repair within 30 days, or by qualifying for the existing delay-of-repair provisions. A deviation of the operational requirement would occur if the applicable repair deadlines are not met and the delay-of-repair provisions do not apply. The proposal also establishes a new framework for addressing recurring or “chronic” emissions events. After the third emissions event or defect from the same cover or CVS within a year, the owner or operator would be required to conduct an investigative analysis within 10 days to determine whether the underlying cause relates to equipment design, operation, maintenance, or prior repair efforts. The results of that investigation would have important compliance implications. If recurring emissions are attributable to a design flaw, EPA would treat the issue as a deviation of the design requirements. If the emissions result from inadequate prior repairs, the deviation would be attributed to the repair requirements. If operations, maintenance, or other site practices are responsible, the deviation would be classified under the operational requirements. EPA would also require implementation of corrective measures identified through the analysis, including design modifications within 90 days and operational or maintenance-related corrective actions within 30 days. Taken together, these revisions would shift the NIE standard away from a framework in which the mere presence of emissions may establish noncompliance and toward one that focuses on whether operators identify emissions, complete timely repairs, investigate recurring problems, and address the root causes of repeated emissions events. IV.    Solicitation of Comment on “Legally and Practicably Enforceable” Standard EPA is also soliciting comment on the definition of “legally and practicably enforceable” (“LPE”), which industry has identified as one of the more problematic existing requirements. Under the 2024 rule, EPA adopted an interpretation of LPE that many commenters argued effectively disqualifies numerous state regulatory programs, permits, and other federally enforceable mechanisms from serving as the basis for remaining below applicable Subpart OOOOb storage tank thresholds. In particular, stakeholders have asserted that the current LPE framework makes it difficult for state air permitting programs and other state regulatory requirements to satisfy EPA's criteria, thereby causing more storage tanks and other emission units to remain subject to Subpart OOOOb requirements than would otherwise be the case. EPA now requests comment on whether its current interpretation of LPE is overly restrictive and whether alternative approaches would better account for the manner in which state permitting and regulatory programs are administered and enforced. The request is significant because a broader interpretation of LPE could allow a wider range of federally enforceable state permits and regulatory requirements to satisfy exemption criteria under OOOOb, potentially reducing the number of storage tanks and other sources subject to direct NSPS regulation. As a result, the LPE issue has implications that extend beyond compliance mechanics and could materially affect the scope of sources regulated under the federal methane program. V.    Revised Requirements for Marginal Wells EPA is also proposing significant revisions to the treatment of lower-producing wells under Subparts OOOOb and OOOOc. The agency notes that marginal wells constitute a substantial portion of the nation’s producing well inventory but account for a relatively small share of overall production. At the same time, EPA discusses studies estimating that marginal wells contribute a disproportionate share of methane emissions from oil and natural gas production. The agency is evaluating whether the 2024 rule appropriately accounts for the operational characteristics, emissions profiles, and compliance costs associated with these wells. To address those concerns, EPA is proposing two alternative approaches to well-site subcategorization. Under the first option, EPA would distinguish between marginal and non-marginal well sites. EPA proposes to define a marginal well as a well that produced no more than 15 barrels of oil equivalent (“BOE”) per day over the prior 12-month period and a marginal well site as a site consisting exclusively of marginal wells with total site-wide production of no more than 15 BOE per day over the same period. EPA is also soliciting comment on whether marginal wells should be further subdivided based on production levels, including a potential distinction between sites producing 6 BOE per day or less and sites producing more than 6 BOE but no more than 15 BOE per day, which could result in additional regulatory flexibility for the lowest-producing wells. Under the second option, EPA would distinguish between conventional and unconventional well sites and tailor requirements based on that classification, including reduced requirements for conventional wells. The agency is seeking comment on which framework better reflects the operational and emissions characteristics of different well sites, as well as whether additional subcategories should be established within the marginal-well population and the extent to which compliance requirements should differ among categories. VI.    LDAR, Pneumatic Controllers, Control Device Monitoring, and Facility Modifications EPA's proposal also includes several targeted revisions to the 2024 rule's leak detection and repair (“LDAR”) requirements. Most notably, EPA proposes additional flexibility in the use of advanced monitoring technologies and seeks to move away from compliance frameworks that rely heavily on a single detection method. The agency is proposing changes intended to facilitate the use of multiple monitoring technologies, including optical gas imaging and other alternative detection approaches, and is seeking comment on whether technology-neutral compliance options can achieve equivalent emissions reductions at lower cost. EPA also proposes revisions for components and equipment that are particularly difficult to monitor using conventional LDAR methods, reflecting concerns that certain 2024 requirements may not be practical or cost-effective in the field. More broadly, EPA questions whether some of the monitoring frequencies adopted in 2024 appropriately balance compliance burdens and emissions-reduction benefits and seeks comment on additional opportunities to tailor LDAR obligations based on emissions risk and source characteristics. EPA also proposes technical revisions to requirements governing control devices and related equipment. These include changes addressing continuous pilot-flame requirements, flame-monitoring data deviations, control-device alerts, visible-emissions test conditions, temporary or backup control devices, temporary process controllers, and control-device categories. The agency’s stated objective is to provide additional compliance flexibility while maintaining appropriate emissions controls. The practical effect will depend on the final requirements and the equipment and circumstances to which each amendment applies. The proposal also addresses pneumatic controllers and equipment leaks at gas processing plants. For certain high-pressure process controllers at transmission compressor stations, EPA proposes a separate regulatory approach based on its reassessment of technical feasibility and cost. The proposal should not be read as establishing a general exemption for pneumatic controllers across the industry. EPA also proposes changes to other equipment-specific requirements, including requirements applicable to pumps, storage vessels, and equipment leaks at gas plants, in response to concerns raised following promulgation of the 2024 rule. Finally, EPA proposes changes to certain requirements governing liquids unloading and other well-site operations, as well as technical corrections and clarifications to the existing regulatory text. These provisions form part of EPA’s broader effort to address implementation concerns and reassess the costs and expected emissions reductions associated with selected requirements in the 2024 rule. Operators should evaluate the specific proposed amendments applicable to their facilities rather than assume that the proposal would provide across-the-board relief from existing monitoring, equipment, or control-device obligations. VII.    Implications for States and Future Congressional or Administrative Action EPA’s proposal would substantially revise several consequential elements of the 2024 methane rule, but it would not eliminate regulation of existing oil and natural gas sources under Clean Air Act § 111(d). As a result, states remain subject to the existing obligation to develop and submit plans for existing sources. If the proposed revisions are finalized, states currently developing those plans may need to reevaluate key program elements, including requirements relating to associated gas, well-site subcategories, the Super Emitter Program, and other compliance obligations. The proposal does not itself extend the January 22, 2027 deadline for state-plan submissions established under the existing framework. The Congressional Review Act (“CRA”) remains a potential source of uncertainty. Depending on when EPA submits a final rule to Congress and the applicable congressional-session timing, a future Congress and President could seek to disapprove the rule under the CRA. A successful disapproval would invalidate the rule and generally restrict the agency from issuing a rule in substantially the same form absent subsequent statutory authorization. The CRA’s lookback provisions can affect the period during which a rule remains subject to congressional review, so the risk cannot be assessed solely by reference to the calendar year in which the rule is finalized. The timing of finalization and submission to Congress, together with the applicable congressional calendar, will determine the extent of that exposure. Finally, unlike the CRA, which can nullify a recently promulgated rule through legislative action, a future administration seeking to unwind this rule would generally need to proceed through a new notice-and-comment rulemaking. EPA would need to revisit the underlying BSER determinations, cost analyses, technical feasibility findings, and enforceability conclusions that support the final rule. Because this proposal is grounded heavily in findings regarding achievability, legal and practical enforceability, and cost-effectiveness, a future administration would need to develop a sufficient record supporting different conclusions before reinstating more stringent requirements. Consequently, the final rule may prove more durable than prior pendulum swings, even if it remains politically controversial.

Event/Resource

Corporate Counsel Symposium 2026 Materials Hub

Materials Symposium Agenda Sessions 8:30 am - 9:30 am CT Session A: The Corporate Compass: Finding True North When Ethical Duties Conflict Philip Kaplan, Senior Legal Counsel, Howden Re Lucia Suljic, Vice President, Corporate Legal, Canon USA Nicole Stanton, Partner & Deputy General Counsel, Dorsey & Whitney LLP This panel addresses ethical obligations of in-house counsel, including balancing obligations and duties that may conflict with each other. How should a responsible in-house lawyer deal with those challenging situations? Rather than stick to an academic discussion, this panel will revolve around a series of practical scenarios that are designed to be realistic and timely, including situations where counsel is asked to represent both the company and an individual, how and when to disclose uncomfortable facts and inconvenient documents, issues involving changing firms and companies, and multijurisdictional practice. The panel will feature discussion from two experienced in-house lawyers and Dorsey’s Deputy General Counsel. Session B: Managing Rapid Regulatory Change in International Trade and Cross-Border Investment Nathan Brower, Executive Vice President, General Counsel, Nature’s Sunshine Greg Ogunsanya, Senior Vice President, General Counsel and Corporate Secretary, H.B. Fuller Kathryn Wood, Senior Vice President & General Counsel, DecoPac, Inc. Dave Townsend and Lawrence Ward, Dorsey & Whitney LLP This program is designed for attorneys advising on cross-border transactions, international trade, regulatory compliance, and corporate governance matters. Panelists will examine recent developments in U.S. trade and investment law and policy, as well as their impact on international collaborations, corporate compliance, and mergers and acquisitions. The discussion will explore how general counsel and in-house legal teams assess and manage evolving trade-related risks within their organizations. Particular focus will be given to developments during the first two years of the second Trump Administration, including changes in tariff policy, tariff refunds, export controls, economic sanctions, and national security reviews of foreign investment. Through a discussion of regulatory trends and practical case studies, attendees will gain a deeper understanding of the legal risks and compliance obligations associated with cross-border business activities, and hear about practical strategies for advising clients and managing compliance obligations in a rapidly changing trade and investment environment. 9:45 am - 10:45 am CT Session A: The Elon Musk Cases: What Tesla and Twitter Can Teach Your Board of Directors Loren Unterseher, Managing Partner, Oxbow Industries, LLC Shulamite White, Chief Legal Officer and Head of People, Motive Technologies Kirsten Schubert, Tom Swigert, and Jonathan Van Horn, Dorsey & Whitney LLP Recent cases involving Elon Musk and his businesses have had significant impact on principles governing board of directors’ fiduciary duties and corporate processes. This panel will examine recent litigation involving Elon Musk, Tesla, and Twitter, and its effects on the law governing the duties of directors and executives, including the executive compensation and director compensation processes, conflicts that may arise when a single executive has control over multiple businesses, and the ramifications of tweets or other public statements by an executive. Session B: All Eyes on DEI: Managing Diversity Efforts Amid Regulatory Scrutiny and Potential Litigation Maggie Dalton, Senior Commercial Attorney, Cargill; Board Co-Chair, Twin Cities Diversity in Practice Laura A. Vannelli, Legal Counsel, Mayo Clinic Susan Lorenc and Jack Sullivan, Dorsey & Whitney LLP The legal and regulatory landscape surrounding diversity, equity, and inclusion (DEI) initiatives has changed dramatically over the past two years. Law firms and legal departments are continuing to grapple with how to recruit, retain, and develop talent from a wide range of personal backgrounds, in a world where previously accepted recruiting and employment practices are facing increased scrutiny and litigation. This program will provide a practical overview of the current legal regime, including recent federal enforcement actions and litigation trends associated with DEI initiatives. Panelists will discuss practical ways in which organizations can pursue and retain legal talent and increase inclusion while minimizing legal, business, and reputational risk. 11:00 am - 12:00 pm CT Session A: Governance in an Age of Increasing Unpredictability James Chosy, Senior Executive Vice President and General Counsel, U.S. Bancorp Todd Hartman, Executive Vice President and Chief Legal and Risk Officer, Best Buy Co., Inc. Alan Rosselot, Associate General Counsel & Assistant Secretary, Delta Air Lines, Inc. Cam Hoang and Robert Rosenbaum, Dorsey & Whitney LLP More than ever, ensuring that boards are well-informed and forward-thinking is critical to a company’s success. Join our panel of corporate governance experts as they share their experiences advising boards through crisis and unpredictable events; capitalizing on, but also checking, disruptive technologies; and positioning the company to succeed in an environment of shifting government priorities. Session B: A Day in the Life of a Trademark, Copyright & Advertising Attorney: A Hypothetical Case Study Alexander Kim, Vice President and General Counsel, Binks Nate Whitaker, Chief Legal Officer and General Counsel, Crumbl Cathy Dahl and Tiffany Shimada, Dorsey & Whitney LLP What issues are companies facing daily while developing rights in intellectual property, protecting those rights, and staying in compliance with myriad potential issues related to advertising, social media, relationships with influencers, and environmental or governmental claims? This panel will feature two in-house counsel who are navigating these issues, utilizing a hypothetical case study, with the support of two Dorsey attorneys helping to develop a roadmap for meeting business objectives and minimizing the risk of claims. 12:00 pm - 1:15 pm CT Keynote Address Dr. Rebecca Heiss, Stress Physiologist Dr. Rebecca Heiss is a stress physiologist, author, and sought-after speaker who helps audiences transform fear and stress into fuel for greater performance and resilience. Her research has been recognized as “transformative” by the National Science Foundation, and she is the author of two books, Springboard and Instinct. Through her Fear(less) message, Rebecca inspires audiences with practical, science-based strategies to train our brains to work for us – not against us – and navigate change and uncertainty with greater confidence.