This update reviews material U.S. legal and regulatory developments as of September 1, 2026.

Commerce issued the final results of its second expedited sunset review of the countervailing-duty order on welded line pipe from Türkiye, effective September 1. Commerce concluded that revocation would likely lead to continuation or recurrence of countervailable subsidies. Because neither the Government of Türkiye nor a respondent interested party submitted an adequate substantive response, Commerce conducted an expedited 120-day review.

Commerce identified subsidy rates likely to prevail if the order were revoked as 152.98% for the Borusan group, 1.31% for the Tosçelik/Tosyalı group, and 1.31% for all others. These are sunset-review rates used for Commerce's statutory likelihood analysis; they are not newly imposed cash-deposit rates. The existing CVD order remains operative unless and until the complete statutory sunset process, including the ITC injury analysis, supports revocation.

Turkish pipe manufacturers, U.S. importers, pipeline developers, and EPC and construction suppliers should not assume this trade-remedy exposure is about to disappear. Existing supply contracts should continue allocating CVD deposits, final-assessment risk, scope and origin cooperation, and post-entry adjustments. Borusan-related transactions require particular care because the 152.98% figure may create misleading commercial assumptions if treated as a current deposit rate. This proceeding is distinct from other Turkish welded-pipe AD/CVD matters reported previously.

Source: Federal Register — Welded Line Pipe from Türkiye sunset review

An FDIC interim final rule became effective September 1, implementing Section 902 of the 21st Century ROAD to Housing Act. The former reciprocal-deposit exception generally capped non-brokered treatment at the lesser of $5 billion or 20% of an institution's liabilities. The amended regime substitutes a tiered liability-based calculation that can reach $30 billion and expands the relevant agent-institution eligibility route to include well-capitalized institutions with a CAMELS composite rating of 3, rather than only ratings 1 or 2.

Qualifying reciprocal deposits are excluded from brokered-deposit treatment under Section 29 of the Federal Deposit Insurance Act. The FDIC estimates that insured institutions held approximately $462.8 billion of reciprocal deposits as of March 2026. Supplemental Call Report instructions will apply for the September 30 reporting period, and comments on the interim rule are due October 1, 2026.

Community and regional banks gain greater capacity to attract large insured deposits through reciprocal networks without the same brokered-deposit classification consequences. That can support additional balance-sheet capacity for commercial real-estate, construction, and business lending over time, although the rule does not itself require increased lending. Banks should recalculate statutory caps, update treasury and liquidity policies, and distinguish regulatory classification from actual liquidity and concentration risk.

Source: Federal Register — Reciprocal Deposits and the ROAD to Housing Act

The SEC proposed Transfer Agent Rules, File No. S7-2026-30, on September 1. The agency describes the proposal as a broad modernization of a regulatory framework that has not been substantively updated since the late 1970s and early 1980s. The proposal addresses electronic recordkeeping and communications and expressly contemplates blockchain technology in securities offerings and share transfers. It would amend existing rules and forms, rescind one rule, and introduce two new transfer-agent rules.

The reform would update transfer processing, recordkeeping, safeguarding, registration, and compliance requirements to reflect the much broader role transfer agents now perform in securities issuance, ownership records, and settlement infrastructure. Comments are due 60 days after Federal Register publication.

Public companies, private issuers using registered transfer agents, securities intermediaries, and businesses developing tokenized or blockchain-based securities infrastructure should follow this rulemaking. Issuer–transfer-agent agreements, cap-table controls, restrictive-share transfer procedures, electronic record custody, and business-continuity arrangements may ultimately require revision. M&A and corporate-reorganization counsel should also track the final treatment of restricted securities and transfer mechanics because transfer-agent compliance can directly affect closing and post-closing share movements.

Sources: SEC Transfer Agent Rules, S7-2026-30 and SEC modernization announcement

The Cost Accounting Standards Board published a final rule rescinding CAS 407, Use of Standard Costs for Direct Material and Direct Labor, effective October 1, 2026. The Board concluded that GAAP has evolved so that most CAS 407 requirements are duplicative. Limited provisions concerning standard costs and variances at the production-unit level that GAAP does not adequately address are moved into CAS 418.

The rule eliminates 12 of CAS 407's 16 individual requirements and almost 2,000 words of regulatory text. Contractors remain subject to CAS 401 consistency requirements and applicable disclosure and contract clauses. The Board states that subsequent changes in standard-costing or variance practices generally will be unilateral accounting-practice changes, rather than automatically required changes merely because CAS 407 has been rescinded.

Defense, construction, engineering, EPC, and infrastructure contractors performing CAS-covered federal contracts should update accounting manuals, disclosure statements, and compliance matrices before October 1. This is genuine deregulation, but it does not permit changes to costing methodologies without cost-impact analysis. Together with the CAS threshold increases reported previously, the amendment further reduces barriers for mid-sized and nontraditional businesses entering federal procurement.

Source: Federal Register — CAS 407 final rule

The FTC and attorneys general of 22 states filed a federal action against Amazon alleging deceptive and unfair conduct in its advertising auctions. The government alleges that Amazon represented its advertising system as a generalized second-price auction while secretly adding a “soft reserve price” or other surcharge that caused Sponsored Products advertisers to pay their own winning bid approximately 80% of the time by 2024. More than one million advertisers are alleged to have been affected, including more than 500,000 small and medium-sized businesses.

The complaint alleges that approximately 1.2 million U.S. advertising customers were affected and that the pricing mechanism may have extracted more than $20 billion from advertisers. These remain allegations; no court has determined liability. The case is pending in the U.S. District Court for the Western District of Washington.

The case is an important compliance signal for marketplaces, ad-tech companies, SaaS platforms, and businesses using algorithmic pricing. Customer-facing descriptions of auctions, dynamic pricing, reserves, fees, and surcharges should match the actual algorithmic mechanism. Internal product changes that materially alter pricing economics should be reviewed for FTC Act and state UDAP exposure before deployment. Companies spending material sums on Amazon advertising should preserve bidding, invoice, and campaign data, although the complaint presently creates no established reimbursement entitlement.

Sources: FTC lawsuit announcement and FTC and states' complaint

The developments combine trade-remedy continuity, greater banking funding flexibility, potential securities-infrastructure reform, reduced CAS requirements, and a significant algorithmic-pricing enforcement action. Businesses operating across procurement, banking, capital markets, and digital platforms should treat them as practical compliance and transaction-planning considerations.

This publication is for general informational purposes only and does not constitute legal advice. Regulatory requirements and legal consequences depend on the applicable facts, contracts, institution, and jurisdiction.