Policies and Procedures

News & Analysis as of

2015 Trends: #9 Technology-enabled ethics and compliance is ready for takeoff

By every indication we are about to witness a dramatic leap in technology-enabled ethics and compliance. Tech Advancement in Key E&C Areas - Trends and our own client experiences are demonstrating that we are...more

Alert: Five Ways to Reduce Your HIPAA Liability

As of early December 2014, 1,170 security breaches under the Health Insurance Portability and Accountability Act (HIPAA) involving 31 million records had been reported to the U.S. Department of Health and Human Services (HHS)...more

This Week In Securities Litigation

The SEC named ratings giant Standard & Poor’s in three actions this week and one of its senior executives in another. The firm settled all three actions, admitting to a series of facts but not violations of the law in one...more

How to Pass the SEC’s Cybersecurity Test in 9 Steps

Cybersecurity again looks to feature prominently on 2015’s regulatory agenda. So far this year, the Financial Industry Regulatory Authority and the SEC’s Office of Compliance Inspections and Examinations (OCIE) have announced...more

Significant Changes to Michigan FOIA Laws Coming In July

Michigan governmental entities will face significant new regulations on how they charge for responses to Freedom of Information Act (FOIA) requests beginning July 1, 2015. ...more

OHCQ Mandates Submission of Policies on Resident Access to Medical Records

Maryland nursing homes must submit their policies and procedures for resident access to and requests for medical records to the Maryland Department of Health and Mental Hygiene's Office of Health Care Quality (OHCQ) by...more

IRS Releases Final Regulations on Requirements for Tax-Exempt Hospitals Under Section 501(r)

On December 29, 2014, final regulations were released under Internal Revenue Code section 501(r). Enacted as part of the Patient Protection and Affordable Care Act in 2010 (the “ACA”), section 501(r) requires tax-exempt...more

OIG updated work plan includes evaluations of CFPB enforcement-related processes and procedures

The Office of Inspector General’s (OIG) work plan, updated as of November 7, 2014, indicates that the OIG’s ongoing projects include audits of the CFPB’s information security program, pay and compensation program,...more

Policy Management FAQs: Top 10 Questions from the Policy Bootcamp Webinar Series Answered

NAVEX Global recently hosted a three-part webinar series on how to take a step-by-step approach to rethinking, implementing and overseeing your policy management life cycle. Webinar attendees asked a number of valuable...more

Gavel to Gavel: Creative compliance

More and more community banks feel the increasing pressures of growing regulatory compliance requirements. To meet those requirements, many banks are turning to creative solutions, ranging from outsourcing compliance...more

Employers: How Prepared Are You for Ebola?

Rapidly changing circumstances raise workplace questions. The Ebola epidemic in 2014 has already been confirmed by the U.S. Centers for Disease Control (CDC) as the worst in history. The extent of this outbreak is...more

OCC Revises Process for Managing Matters Requiring Attention

The Office of the Comptroller of the Currency (OCC) on October 30 published revised policy and procedures for how it manages Matters Requiring Attention (MRAs) resulting from its examination of supervised institutions. MRAs...more

Investigating Employee Wrongdoing

Companies in every industry—private and public—struggle with the difficult task of promptly identifying employee wrongdoing and responding appropriately. The National Football League continues to be embroiled in a controversy...more

Brand Standards Are for Everyone

Now more than ever, it is important to understand brand standards: why they are set; how they affect franchisors, franchisees, and customers; and what the boundaries of brand enforcement policies should be....more

2014-15 Compliance Developments & Calendar for Private Fund Advisers

Introduction - Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more

SEC Charges Broker-Dealer for Failure to Protect Against Insider Trading by Employees

The Securities and Exchange Commission for the first time brought charges against a broker-dealer for failure to adequately protect against insider trading by its employees. The charges stem from a broker’s use of a...more

Corporate Responses to Investigative Requests by the Federal Government

In light of these new realities corporations face, the first step a company should take is to establish internal guidelines addressing interaction with government agents. Companies should have a response policy in place and...more

Freddie Mac Implements FinCEN AML Rules, Updates Other Selling And Servicing Policies

On August 14, Freddie Mac issued Bulletin 2014-15, which reminds seller/servicers subject to the AML requirements of the BSA that they are expected to maintain an AML compliance program and are required to report to Freddie...more

Health Law Wire: OIG Report on Nursing Home Compliance with Federal Regulations for Reporting Allegations of Abuse or Neglect...

The Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services released a report and recommendations for nursing facilities to develop and implement written policies related to reporting...more

OIG Finds Privacy and Security Risks with ONC EHR Certification Process

It is ironic to learn the Office of Inspector General (OIG) believes the Office of the National Coordinator for Health Information Technology (ONC) essentially has an insufficient compliance program to maintain the privacy...more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part III

So, now you’re ready to start your culture audit… Some key questions you want to ask before you start are: Do I have the support of Executive leadership? If not, go back to your E&C steering committee and work through...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part I

We’ve talked a lot in our Tales from the Crypt about the signs to watch for that indicate something’s gone wrong, from minor cultural twists to lapses of integrity that are tantamount to criminal activity. We all wish we had...more

Future-Proof Your Policy Management System with Content Strategy

Compliance teams are paying more and more attention to policy management. From bribery of government officials to sexual harassment and data security, companies have a vested interest in knowing that employees are doing the...more

New York AG, Capital One Agree On Credit Screening Changes

New York Attorney General Eric T. Schneiderman recently announced an agreement with Capital One Financial Corporation that will require the bank to adopt new policies regarding the screening of consumers seeking to open...more

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