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

There is a changing legal landscape across the United States for multi-family property owners and management companies on leasing fees coined “junk fees.” Recently, on March 13th of 2026, the FTC proposed to commence rulemaking to address unfair and deceptive acts or practices related to advertised rent and other fees and charges in the rental housing industry.

FERC’s issuance on June 18, 2026 of tailored show cause orders to all six regional grid operators means changes are likely coming to transmission interconnection rules for large load users. In order to comment, interested parties should file for intervention within 21 days of FERC’s recent issuance to secure the right to comment on RTO proposals when they are filed later.

The Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”) was passed in 2022. That law required covered entities who are part of so-called “critical infrastructure” to report cybersecurity incidents and ransomware payments to the Federal government. For cyber incidents, the law required reporting to CISA within 72 hours and for ransomware payments, the reporting is required within 24 hours—both tight turnarounds.