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Risk Assessment Strategic Enforcement Plan

Sheppard Mullin Richter & Hampton LLP

Elements of Right-Sized Privacy Program: Strategic

One of the biggest difficulties companies may face for effective privacy program implementation arises if they neglect strategy and focus only on the law. Namely, developing policies and procedures that mention legal...more

Latham & Watkins LLP

Principles Guiding FINRA Enforcement Action

Latham & Watkins LLP on

FINRA Enforcement head Susan Schroeder offers member firms clarity on arguments most likely to move FINRA to decline an Enforcement action. The Financial Industry Regulatory Authority (FINRA) relies on a framework of core...more

Locke Lord LLP

The Consumer Financial Protection Bureau: What Insurers Should Know

Locke Lord LLP on

Q: When does the Consumer Financial Protection Bureau (CFPB) have authority over insurance ?companies? The federal legislation commonly known as the Dodd-Frank Wall Street Reform Act, which created the ?CFPB,...more

Davis Wright Tremaine LLP

Upcoming HIPAA Audits May Target Financial Institutions—Here’s How to Prepare

Much like a tornado watch, the conditions appear to be right for a coming storm: the upcoming Phase 2 HIPAA audits. The Department of Health and Human Services Office for Civil Rights (OCR) has begun verifying contact...more

Burr & Forman

FINRA’s 2015 Exam Priorities

Burr & Forman on

The Financial Industry Regulatory Authority (“FINRA”) released its 10th annual Exam Priority Letter earlier this week (Jan. 6, 2015). The so-called “Errico Letter” advises broker-dealer member firms of the operational risks...more

NAVEX

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

NAVEX on

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

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