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In June 2016, AmSurg Corp. and Envision Healthcare Holdings, Inc. (Envision) announced they have signed a definitive merger agreement pursuant to which the companies will combine in an all-stock transaction. Upon completion of the merger, which is expected to be tax-free to the shareholders of both organizations, the combined company will be named Envision Healthcare Corporation and co-headquartered in Nashville, Tennessee and Greenwood Village, Colorado. The company's common stock is expected to trade on the New York Stock Exchange under the ticker symbol: EVHC. Bass, Berry & Sims served as lead counsel on the transaction, led by Jim Jenkins. Read more.

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Inside the FCA blogInside the FCA blog features ongoing updates related to the False Claims Act (FCA), including insight on the latest legal decisions, regulatory developments and FCA settlements. The blog provides timely updates for corporate boards, directors, compliance managers, general counsel and other parties interested in the organizational impact and legal developments stemming from issues potentially giving rise to FCA liability.

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CFTC’s Derivative Rulemaking Under Dodd-Frank Will Extend Into 2012


September 12, 2011

Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") establishes a new regulatory scheme for the over-the-counter derivatives market. As we explained in a prior Alert, this summer, the Securities and Exchange Commission ("SEC") and the Commodity Futures Trading Commission ("CFTC") delayed the compliance deadline for many of the provisions of Title VII. At that time, the effective date was fast approaching, but the agencies had not completed required rulemaking related to the new derivatives regulations. While the SEC’s compliance extension was tied to the completion of applicable rulemaking, the CFTC’s extension was set to expire on December 31, 2011.

On September 8, 2011, the CFTC held an open meeting to discuss proposed rules extending the deadline for swap dealers and major swap participants to comply with new swap clearing and trading, swap dealer documentation, and margining requirements. During the meeting, Chairman Gary Gensler made it clear that the CFTC would not complete its Title VII rulemaking by the extended compliance deadline of December 31, 2011, stating "Let me start by saying that we are focused on considering these rules thoughtfully – not against a clock." Gensler then set forth a tentative timeline for the CFTC to consider derivatives rules, which contained a significant number of items in the first quarter of 2012. Additionally, Gensler stated, "[m]uch like we did on July 14, this fall we also will consider further exemptive relief from the application of Dodd-Frank's Title VII requirements."

It now appears clear that it will be well into 2012 before the CFTC completes all rulemaking under Title VII of the Dodd-Frank Act. In the meantime, the CFTC is likely to provide additional extensions and exemptions on compliance. We will continue to monitor both the SEC’s and the CFTC’s rulemaking under Title VII and provide updates as appropriate.

1  Gary Gensler, Chairman, Commodity Futures Trading Commission, Opening Statement, Meeting of the Commodity Futures Trading Commission (Sept. 8, 2011), available here.

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