Implementing Reg F: What the ARM Industry Should be Doing & Thinking About Now

Join Clark Hill’s Commercial Real Estate attorneys and industry professionals for a timely and dynamic program in Dallas, focusing on the latest challenges and top trends in the CRE industry.

Ever since its initial passage into law in 2024, the Colorado AI Act has been a lightning rod for controversy and calls for change. Over the ensuing two years, multiple attempts to amend the law were floated and proposed by consumer and industry groups. The implementation of the law itself was delayed several times to allow for such changes, with Governor Jared Polis calling a special session of the legislature last August to specifically address potential changes. All of those attempts appear to have culminated in Senate Bill 189 having passed both the Colorado House (57-6) and Senate (34-1) this week. The bill next heads to the desk of Governor Jared Polis where it is expected to be signed into law and to take effect as of January of 2027.

Note: On May 4, 2026, the “General criteria and operational guidelines of an advisory nature to promote investment and tax compliance” (the “Guidelines”) was published in the Federal Register.

The purpose of the Guidelines is to direct administrative action in tax matters, strengthening legal certainty, efficiency, and trust in the relationship between the tax authority and taxpayers, as well as to promote investment, administrative simplification and voluntary compliance.