Understanding Scope of Practice
Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
The California Department of Public Health (CDPH) issued a letter on September 6, 2024, to all general acute care hospitals clarifying the scope of practice for Certified Registered Nurse Anesthetists (CRNAs) following...more
Be cautious, be curious, be vigilant, and be brave. Those were the words of the New York State Bar Association’s Task Force on Artificial Intelligence. It is good advice. GenAI is here and lawyers need to understand its...more
This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more
The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more
Regulator finds that firms could improve how they conduct anti-money laundering checks when dealing with UK PEPs. ...more
On July 10, the Centers for Medicare & Medicaid Services (CMS) proposed to extend virtual direct supervision—i.e., the ability to provide direct supervision through real-time, audio-visual technology (rather than in-person...more
On May 28, 2024, the Chair of the Supervisory Board of the European Central Bank ("ECB"), Claudia Buch, announced the decision to reform the current process of annual review of credit institutions under direct ECB supervision...more
FINRA’s guidance sheds further light on the new rule, which will permit firms to elect “non-branch” designation for a private residence where an associated person conducts specified supervisory activities....more
Cosmetic injections, such as Botox and dermal fillers, and weight-loss injections, such as Wegovy® and Ozempic®, are popular offerings at med spas, weight-loss clinics, and dermatology practices. But are they considered the...more
Baker v. Bunker Hill Haven Home, 12th Dist. Butler No. CA2023-08-095, 2024-Ohio-875 - Todd Howard was a resident at Bunker Hill, a home for wayward boys. He snuck out of the facility to meet with his friends, Zeb Freeman and...more
The Consumer Financial Protection Bureau (CFPB) recently issued a new procedural rule to streamline how it determines which nondepository institutions it has the authority to supervise. According to the CFPB, the new rule...more
In this episode of the #HealthLawHotSpot, host Ericka Adler and fellow Roetzel attorney Christina Kuta discuss limitations on non-physician practitioners in terms of the services they can provide and the role of physicians in...more
On Tuesday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a procedural rule streamlining the designation proceedings for nonbank supervision based on a particular entity posing “risks to consumers.” As...more
On April 16, 2024, the Consumer Financial Protection Bureau ("CFPB" or "Bureau") issued a rule to update its procedures for designating nonbank covered persons for supervision. Section 1024(a)(1)(C) of the Consumer Financial...more
The UK Financial Conduct Authority (FCA) is entering the final year of its 2022-2025 strategy, which features a commitment to be more innovative, assertive and adaptable. Its 2024/25 Business Plan outlines how the regulator...more
In recent times, there has been an increasing trend of supervision by the Israel Securities Authority (ISA) over non-supervised entities. This may seem paradoxical: if these entities are not under supervision, why does the...more
The Consumer Financial Protection Bureau (CFPB) released a procedural rule updating its supervisory process for institutions seeking to appeal a compliance rating or an adverse finding. Although the appeals process remains...more
The CFPB has released a supervisory order which establishes that the CFPB has supervisory authority over World Acceptance Corp. (WAC) based on the CFPB’s conclusion that it has reasonable cause to determine that WAC “is...more
On February 16, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that it is updating its internal supervisory appeals process for institutions seeking to appeal a compliance rating or an adverse...more
On February 23, the Consumer Financial Protection Bureau announced its first decision designating a nonbank lender for supervision based on potential risk to consumers. As the CFPB emphasized in its press release, however,...more
The Federal Financial Institutions Examination Council (“FFIEC”) published a statement on February 12, 2024 regarding “principles for the examination of supervised [institutions’] residential property appraisal and...more
On January 23, 2024, FINRA announced the addition of new Supplementary Material .18 to FINRA Rule 3110 (Supervision) to adopt a voluntary, three-year remote inspections pilot program (Pilot Program) to allow eligible members...more
Firms will be able to treat private residences from which certain supervisory activity is conducted as non-branch offices instead of OSJs. The adoption comes after nearly two years of FINRA efforts to align its supervisory...more
The new rule establishes criteria for firms to elect “non-branch” designation for a private residence where an associated person engages in specified supervisory activities....more
The Florida State Bar recently adopted an advisory opinion meant to provide attorneys with guidance on how to use generative artificial intelligence (“GenAI”) without running afoul of ethics rules. In doing so, Florida...more