News & Analysis as of

Risk Assessment Comment Period

Venable LLP

Federal Banking Agencies Highlight Bank-Fintech Partnership Risks and Invite Comment

Venable LLP on

On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

McDermott Will & Emery

CMMC Level 3: Strict Scoping and Expansive Requirements

McDermott Will & Emery on

In this series of articles, we explore the different certification requirements of CMMC Levels 1, 2 and 3; the impact on contractors and external service providers; and proposed next steps... On December 26, 2023, the US...more

BakerHostetler

EPA Takes Next Step Toward New Formaldehyde Regulations

BakerHostetler on

On March 15, 2024, the United States Environmental Protection Agency (EPA) released the draft risk evaluation for formaldehyde for public comment and peer review. The draft risk evaluation was promulgated pursuant to EPA’s...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

OSHA Proposes Rule to Allow Third Parties to Participate in Workplace Walkaround Inspections

On August 30, 2023, the Occupational Safety and Health Administration (OSHA) published a proposed rule that would change the scope of who would be allowed to participate in walkarounds conducted as part of OSHA inspections. ...more

Cadwalader, Wickersham & Taft LLP

FDIC Proposes Special Deposit Insurance Assessment After Systemic Risk Exception

The Federal Deposit Insurance Corporation (“FDIC”) Board voted (3-2) to propose a special assessment to recoup the expected $15.8 billion cost to the Deposit Insurance Fund “(DIF”) in the wake of invocation of the special...more

Wiley Rein LLP

NTIA Seeks Comment on AI Accountability

Wiley Rein LLP on

Earlier this month, the National Telecommunications and Information Administration (NTIA) published its AI Accountability Policy Request for Comment (RFC). The RFC seeks comment on artificial intelligence (AI) system...more

Perkins Coie

Biden Administration Seeks Comment on How To Improve AI Accountability

Perkins Coie on

The recent dramatic growth of artificial intelligence (AI) technologies continues to be a focus of the Biden administration. The National Telecommunications and Information Administration (NTIA), a federal agency within the...more

Akin Gump Strauss Hauer & Feld LLP

CPPA Approves Final CPRA Regulations, Invites Comments on Future Rulemaking Topics

On February 10, 2023, the California Privacy Protection Agency (CPPA) issued an invitation for public commentary on the topics that will be included in their future rulemaking: cybersecurity audits, risk assessments and...more

WilmerHale

California Privacy Protection Agency Approves CPRA Regulations and Takes Steps to Promulgate Future Rulemaking on Additional...

WilmerHale on

On Friday, February 3, 2023, the California Privacy Protection Agency (CPPA) held a public board meeting at which it voted unanimously to (1) approve the final text of the California Privacy Rights Act (CPRA) regulations and...more

Goodwin

Federal Reserve Seeks Feedback on Proposed Updates to FMUs Risk Management Requirements

Goodwin on

Regulatory Developments - Federal Reserve Seeks Feedback on Proposed Updates to FMUs Risk Management Requirements - On September 23, the Federal Reserve invited comment on proposed updates to operational risk...more

Quarles & Brady LLP

FDA May Require Opioids to be Dispensed with Mail-Back Envelopes and Related Patient Education

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The FDA is requesting public comments on a possible change to the Opioid Analgesic Risk Evaluation and Mitigation Strategy requiring opioid analgesics (OA) used in an outpatient setting to be dispensed with mail-back...more

Jones Day

U.S. Securities and Exchange Commission Releases Proposed Rule on Climate Risk Disclosure

Jones Day on

As previously reported, on March 21, 2022, the U.S. Securities and Exchange Commission ("SEC") proposed amendments to Regulations S-K and S-X that would require registrants to provide certain climate-related information in...more

Sheppard Mullin Richter & Hampton LLP

FinTechs in Crosshairs as CFPB Invokes Dormant Authority to Examine Nonbanks

On April 25, the CFPB announced that it is using its “dormant authority” in order to conduct examinations of nonbanks posing risks to consumers.  The Bureau has direct supervisory authority over banks and credit unions,...more

Bergeson & Campbell, P.C.

Canada Will Publish Draft Framework for Risk Assessment of Manufactured Nanomaterials for 60-Day Comment Period

On December 17, 2021, Canada published the Chemicals Management Plan implementation table for 2021-2024. Under the Canadian Environmental Protection Act, 1999 (CEPA), Canada plans to take the following actions regarding...more

Eversheds Sutherland (US) LLP

New York State Department of Financial Services releases proposed guidance for New York insurers on managing climate risks

Last week (March 25, 2021), the New York State Department of Financial Services (NYDFS) released for public comment proposed guidance for New York domestic insurers on managing financial risks from climate change (the...more

Goodwin

OCC Proposes Rule to Ensure Banks Offer Fair Access to Financial Services

Goodwin on

On November 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a proposed rule with the objective of ensuring banks offer fair access to financial services. Certain banks have received significant...more

Akin Gump Strauss Hauer & Feld LLP

FCC Sets Comment Deadlines for Satellite Orbital Debris Mitigation Rules

- The FCC’s Report and Order and FNPRM on satellite orbital debris mitigation, previously adopted on April 23, 2020, were published in the Federal Register on August 25. - This action now sets an October 9, 2020 deadline...more

Beveridge & Diamond PC

Colombia Proposes New Chemical Regulatory Framework, Comments Due July 31, 2020

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Late last week four Colombian agencies—including the ministries of health (Ministerio de Salud y Protección Social), labor (Ministerio del Trabajo), commerce (Ministerio de Comercio, Industria y Turismo), and the environment...more

Bergeson & Campbell, P.C.

EPA Releases Draft Risk Assessments for Paraquat Dichloride

On October 15, 2019, EPA posted a total of 11 documents to the registration review docket for paraquat dichloride (EPA-HQ-OPP-2011-0855). Of primary interest in the registration review process under the Federal Insecticide,...more

Faegre Drinker Biddle & Reath LLP

New Proposed Cybersecurity and EHR Donation Rules

On October 9, 2019, the U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) simultaneously released a set of proposed rules (the “Proposed Rules”) that, among other...more

Stinson LLP

Draft Risk Evaluations Released for HBCD and 1,4-Dioxane

Stinson LLP on

Recently, the U.S. Environmental Protection Agency (EPA) released draft risk evaluations for cyclic aliphatic bromide cluster (HBCD) and 1,4-Dioxane, triggering a 60-day public comment period. ...more

Hogan Lovells

FDA issues benefit-risk framework for assessing opioid drug applications, announces public meeting

Hogan Lovells on

Agency seeks input on “comparative advantage” requirement for new opioids - Yesterday, as part of its ongoing efforts to combat the current opioid crisis, FDA published a draft guidance, “Opioid Analgesic Drugs:...more

Davis Wright Tremaine LLP

Oregon Air Toxic Sources Need to Focus on Their Priority and Plan

Oregon moved to regulate air toxics with SB 1541, which became effective April 10, 2018. Regulations implementing the air toxics requirements were adopted by Oregon DEQ in November of 2018 and, as explained below, draft risk...more

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