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Policies and Procedures

OCC's High-LTV Bulletin Is a Win for Banks and Consumers

by Pepper Hamilton LLP on

Since the financial crisis, it has been difficult for consumers and developers to obtain mortgages to buy and build in the areas most hurt by the recession. The Office of the Comptroller of the Currency (OCC) has...more

North Carolina Law Requires Nurses to Comply with Police Demand for Blood Draw

The drawing of blood by healthcare providers for law enforcement purposes has been big news lately. In June, the North Carolina Supreme Court held in a case of first impression that North Carolina’s implied consent statute...more

Ethics and Compliance Training, What Gets Results?

The following interview is with Dr. Patricia Harned, Chief Executive Officer of the Ethics & Compliance Initiative (ECI). RB: Pat, it’s a pleasure to have you join us today, and thank you for sharing your report “Ethics...more

OCIE Releases Results of Cybersecurity Examination Initiative

On August 7, 2017, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a summary of its observations (the report) from cybersecurity examinations of 75...more

EMTALA Settlement Highlights Continuing Challenges for Hospitals

After 30 years as a fixture in the federal healthcare regulatory landscape, the Emergency Medical Treatment and Labor Act—more commonly known as EMTALA—has been in the news again. In the past year, the U.S. Department of...more

Responding To Violence In the Workplace – A “Catch 22” For Employers

by SmithAmundsen LLC on

The recent instances of violence in the workplace remind us of the complex task facing employers. Employers must maintain a safe work environment for employees while operating within the parameters of the many federal and...more

The Perfect Compliance Combo: Culture and Controls

by Michael Volkov on

Compliance practitioners divide their commentary and insights into two general categories – ethical culture and compliance controls. It is easy to divide compliance issues into these two categories. Ethical culture articles...more

OIG Settles EMTALA Allegations Involving Psychiatric Care

On June 2, 2017, AnMed Health and the Office of Inspector General (OIG) for the United States Department of Health and Human Services agreed to a $1.295 million settlement of allegations that AnMed had violated the Emergency...more

Arizona Corporation Commission Making Progress on New Utility Policies Affecting Water Loss, CIAC and CC&Ns

by Snell & Wilmer on

The Arizona Corporation Commission is addressing new policies that could affect a variety of regulated utilities in Arizona in the near future. The policies are intended to provide guidance on issues that are often points of...more

Cyber Law Tracker: New Connecticut Cybersecurity Strategy

by Pullman & Comley, LLC on

As its next step in the creation and implementation of a cybersecurity plan, the State of Connecticut has created a Cybersecurity Strategy document. This strategy specifically highlights the roles and vulnerabilities of state...more

Worksite Notices, Who Needs ‘Em?

Well, if you are an organization that has employees, you do! Although they may be a bit unappealing and often overlooked, worksite notices are required under both federal and state law. In fact, many municipalities and cities...more

Use of Text Messaging Should Change the Nature of Evidence Gathering in Internal Investigations

It doesn’t take a millennial to know that these days not all pertinent business-related communications are to be found on corporate e-mail servers. As we have increasingly seen in recent internal investigations, the most...more

No Good Deed Goes Unpunished: When Well-Intentioned School Policies Actually Create Risks

by Fisher Phillips on

There’s no question that today’s social and political climate has affected school campuses across the country in ways that have not been experienced in decades. A steady increase in the diversification of student bodies...more

Technically Speaking, Cybersecurity Isn’t About Speaking Technically

by Seyfarth Shaw LLP on

These days cybersecurity seems to be all about technology. Pen testing, firewalls, port scanning, SIEM, zero-day, IPS, AES256, SHA, DMZ, NIDS, TLS, SS7 – I’ll stop. I could go on, but you get the idea. And I have a vested...more

New Rules: OCR Issues Internal Memorandum Impacting Enforcement Practices for Pending and Future Investigations

by Shipman & Goodwin LLP on

Earlier this month, the U. S. Department of Education, Office for Civil Rights’ Acting Assistant Secretary issued an internal memorandum to Regional Directors eliminating certain existing internal procedures and detailing new...more

Second Circuit Upholds NLRB Whole Foods Decision Allowing Employee Recording in the Workplace

by Franczek Radelet P.C. on

With little fanfare, the Second Circuit Court of Appeals recently upheld a National Labor Relations Board decision striking down Whole Foods’ policies prohibiting workplace audio or video recording without prior approval from...more

The Uber Board Report – Part II: Internal Controls

by Thomas Fox on

I continue my blog post series on the Holder Report (Report) to the Board of Directors of Uber Technology, Inc. (Uber) where the Board asked Holder’s law firm, Covington & Burling LLP (Covington), to evaluate three issues:...more

Above the Clouds: Jeweler’s Trade Secret Spat Highlights Risk of Employee-Controlled Cloud Storage

We have discussed before the importance of maintaining internal policies and procedures to protect the security and integrity of cloud-based repositories. A recent case in the U.S. District Court for the District of Maryland...more

Practical Tips for Maintaining Dignity During Termination Meetings: Everybody Wins

by Foley & Lardner LLP on

This past week, the nation was shocked with yet another senseless act of violence in the workplace. On Monday, a disgruntled former employee, walked into his former employer’s job site and killed 5 of his former co-workers...more

Are We Being Taped? – The Second Circuit Weighs in on Workplace Taping

by Kelley Drye & Warren LLP on

In the era of the ever-present cell phone, where many people seem to video and record (and then post to social media) virtually everything that goes on in their lives, employers have tried to limit such activity in the...more

FCPA Compliance Report-Episode 331, Chris Morton

by Thomas Fox on

In this episode, I visit with Chris Morton, the SVP, Marketing and Corporate Development for Navex, about the firm’s new resource for the Compliance Community, ComplianceNext.com. It is a free, compliance community driven...more

Record-Setting Target Settlement Changes Expectations for Institutional Data Security

On May 24, 47 state attorneys general settled with Target for $18.5 million regarding its 2013 data breach. The implications of the agreement may be more far-reaching than many companies realize. The fact that nearly all...more

Ensuring Compliance with Controls

by Michael Volkov on

Let’s start with some basics – a public company is required to implement a set of internal controls. A compliance program is a critical part of a company’s internal controls. A company’s compliance program is only as...more

Goodbye to the Midnight Rider and the HR Gap Analysis

by Thomas Fox on

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

Grant and cooperative-agreement recipients: Are your procurement standards compliant yet?

by Thompson Coburn LLP on

Local governments, Native American tribes, institutions of higher education, or non-profit organizations (including health care organizations) that receive grants or cooperative agreements (or part of either type of Federal...more

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Cybersecurity

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