Self-Reporting

News & Analysis as of

The Clock is Ticking on the SEC’s MCDC Initiative - Limited Self Reporting Window Closes September 9, 2014

The U.S. Securities and Exchange Commission (the “SEC”) has announced its Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”) for municipal issuers, conduit borrowers, other obligated persons...more

Low-Tech Proof In a High-Tech World: Northern District of California Denies Class Certification In Hulu Data Privacy Case

On June 16, the Northern District of California denied a motion for class certification in In re Hulu Privacy Litigation, No. C 11-03764 LB, ECF No. 111. The plaintiffs in that action alleged that Hulu violated the Video...more

SEC’s Self-Reporting Program to Correct Misstatements Regarding Continuing Disclosure Compliance Set to Expire on September 10,...

The Securities and Exchange Commission’s Municipalities Continuing Disclosure Cooperation Initiative provides an opportunity for municipal bond issuers, borrowers and underwriters to correct misstatements in offering...more

New SEC Initiative Offers Municipal Issuers and Underwriters an Exit Strategy for Continuing Disclosure Violations

The U.S. Securities and Exchange Commission Enforcement Division recently announced a program intended to resolve violations of federal securities laws regarding continuing disclosures in bond offering documents. The program,...more

CME Launches Website Links for Complaints and Self-Reports

CME Group’s website has added hyperlinks that allow persons to file complaints or self-report potential rule violations. ...more

Comments Due for New Expedited Review Process for CMS's Voluntary Self-Referral Disclosure Protocol (SRDP)

The creation of the SRDP through the Affordable Care Act as a mechanism to resolve potential Stark violations was welcomed by the industry. However, since enactment of the regulations implementing the SRDP in 2010, the volume...more

SEC Launches Cooperation Initiative to Encourage Municipal Issuers and Underwriters to Self-Report Continuing Disclosure...

On March 10, 2014, the Securities and Exchange Commission ("SEC") announced that issuers and underwriters of municipal securities may voluntarily report materially inaccurate statements made in offering documents regarding...more

SEC Initiative Encourages Continuing Disclosure Violation Self-Reporting By Issuers And Underwriters

HIGHLIGHTS - - The Municipalities Continuing Disclosure Cooperation Initiative (MCDC Initiative) begun by the SEC's Enforcement Division encourages issuers, borrowers or underwriters to self-disclose potential...more

SEC Encourages Self-Reporting of Continuing Disclosure Misstatements

In an effort to increase enforcement of continuing disclosure obligations, the Securities and Exchange Commission (“SEC”) announced a self-reporting program on March 10, 2014, referred to as the Municipalities Continuing...more

SEC Enforcement Division Encourages Self-Reporting by Municipal Securities Issuers and Underwriters

Yesterday, the Securities and Exchange Commission’s (SEC) Enforcement Division introduced an initiative to encourage self-reporting by municipal securities issuers and underwriters of possible securities law violations...more

OFCCP’s New Voluntary Self-Identification Requirements

Federal contractors must invite job applicants and employees to voluntarily self-identify as individuals with disabilities using a form that was recently released by the Office of Federal Contract Compliance Programs (OFCCP)....more

Federal Contractor Affirmative Action Regulations Take Effect March 24, 2014

New regulations issued by Department of Labor's Office of Federal Contract Compliance Programs take effect March 24, 2014. Requirements include establishing hiring benchmarks for veterans and adopting utilization goals for...more

CFPB’s New ‘‘Responsible Conduct’’ Guidelines: Will They Incentivize Greater Self-Reporting And Self-Regulation By Consumer...

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB or the Bureau) issued CFPB Bulletin 2013-6, titled ‘‘Responsible Business Conduct: Self-Policing, Self-Reporting, Remediation, and Cooperation.’’ The CFPB...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

FHA Issues Mortgagee Letter Clarifying Lender Self-Reporting Requirements

Possibly in response to the CFPB's recent emphasis on self-reporting, FHA issued Mortgagee Letter 2013-41 last week, which clarifies the self-reporting requirements for Single Family FHA-approved lenders. Ballard Spahr has...more

Corporate Criminal Liability – Interview with Bridget Rohde, Member, Mintz Levin [Video]

Attorney Bridget Rohde, Member of Mintz Levin's Litigation Practice, discusses corporate criminal liability for the actions of employees and how companies can protect themselves....more

Offshore Account holders Need to “Know When to Fold’em”

Kenny Rogers is known for his rendition of the song “The Gambler” (The Gambler lyrics © Sony/ATV Music Publishing LLC) which contains the refrain “You gotta know when to hold’em and know when to fold”em” . The song could not...more

A New Era of Canadian Anti-Corruption Enforcement?

This year has been a watershed in terms of Canada’s enforcement of its Corruption of Foreign Public Officials Act (“CFPOA”): • In January 2013, a record fine of CAD 10.35 million (USD 10.27 million) was imposed on...more

Peggy Twohig of CFPB clarifies its expectations about self-reporting violations of law

My colleagues, Chris Willis and Barbara Mishkin, have previously blogged here and here about the CFPB’s recent guidance advising banks and non-banks subject to its jurisdiction to investigate and self-report to the Bureau...more

U.S. Government Releases Draft Self-Regulatory Code of Conduct for Mobile App Privacy Notices

The National Telecommunications and Information Administration (NTIA) has published a draft of self-regulatory guidelines for privacy notices for mobile apps. This version is for companies that participated in the process of...more

CFPB Offers Potential Benefits If You Turn Yourself In, But Make Sure You Understand Your Options

Brownstein Hyatt Farber Schreck’s past Client Alerts have warned that the Consumer Financial Protection Bureau’s reach touches virtually every company that has any interaction with consumers. A recent Bulletin issued by the...more

Foundations in Fraud and Abuse: Building Blocks of Health Law

The Ober|Kaler Health Care General Counsel Institute is pleased to introduce its Foundations series, a collection of programs designed to equip in-house counsel with a solid foundation in the cornerstones of health law. The...more

Right from the Source: IRS Guidance for U.S. Plan Sponsors on Fixing Mistakes and Surviving IRS Employee Plan Audits

Those of you who participated in our July 16 webinar on plan fix-it programs heard us emphasize the importance of self-audits and internal controls to increase your chances of coming out clean in an employee plan audit....more

How to Be a Good Corporate Citizen CFPB Style

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2013-06 identifying “responsible business conduct” that may impact the exercise of its “enforcement discretion.” The Bulletin specifies the...more

CFPB Encourages Self-Policing And Self-Reporting

The CFPB has issued a bulletin encouraging self-policing, self-reporting, remediation, and cooperation....more

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