Nutter Bank Report: September 2019

Nutter McClennen & Fish LLP


  1. FDIC Adopts Final Rule Establishing Community Bank Leverage Ratio Framework
  2. OCC Issues Compliance Guidance on Registered Appraisal Management Companies
  3. CFPB Announces New Policies to Promote Innovation in Consumer Financial Services
  4. House Approves Bill to Provide Safe Harbor for Banks that Service Marijuana Businesses
  5. Other Developments: Examination Surveys and Deposit Insurance Applications

1. FDIC Adopts Final Rule Establishing Community Bank Leverage Ratio Framework

The FDIC has issued a final rule that introduces an optional, simplified measure of capital adequacy for qualifying community banking organizations known as the “community bank leverage ratio” or CBLR. According to the FDIC, the CBLR framework released on September 17 is designed to reduce regulatory reporting burden by removing the requirements for calculating and reporting risk-based capital ratios for qualifying community banking organizations that opt into the framework. To qualify for the CBLR framework, a community banking organization must have a tier 1 leverage ratio that is more than 9%, less than $10 billion in total consolidated assets, and limited amounts of off-balance-sheet exposures and trading assets and liabilities. A qualifying community banking organization that opts into the CBLR framework and continues to maintain a tier 1 leverage ratio of more than 9% will be considered to have satisfied the risk-based and leverage capital requirements in the generally applicable capital rule and will be considered to have met the well-capitalized ratio requirements under the Prompt Corrective Action regulations. Such a qualifying community banking organization will not be required to report or calculate risk-based capital. The final rule becomes effective on January 1, 2020, provided that it is also adopted by the OCC and the Federal Reserve as expected. The CBLR framework will be available for banks to use in their March 31, 2020 Call Reports. Click here for a copy of the final rule.

Nutter Notes: The final rule includes a two-quarter grace period during which a qualifying community banking organization that temporarily fails to meet the qualifying criteria, including the greater than 9% leverage ratio requirement, generally would still be deemed well-capitalized so long as the banking organization maintains a leverage ratio greater than 8%. At the end of the grace period, the banking organization must meet all qualifying criteria to remain in the community bank leverage ratio framework or otherwise must opt out of the CBLR framework. The FDIC also issued a final rule on September 17 that permits non-advanced approaches banking organizations to use the simpler regulatory capital requirements for mortgage-servicing assets, certain deferred tax assets arising from temporary differences, investments in the capital of unconsolidated financial institutions, and minority interest when measuring their tier 1 capital as of January 1, 2020. Finally, the FDIC issued another final rule on the same day that makes technical changes to incorporate the CBLR framework into the deposit insurance assessment system. A bank that uses the CBLR framework will not have any changes in how its assessment rate is calculated.

2. OCC Issues Compliance Guidance on Registered Appraisal Management Companies

The OCC has published new guidance to remind national banks and federal savings associations of the new registration requirement for appraisal management companies (“AMCs”) that became effective on August 10, 2019. The OCC’s guidance issued on September 16 explains that, under Section 1473 of the Dodd–Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and its implementing regulations, an AMC may not provide appraisal management services to a bank for most consumer credit transactions secured by a consumer’s principal dwelling if the AMC is not registered in the state or states in which it does business unless the AMC is subject to oversight by a federal financial institutions regulatory agency (i.e., the AMC is owned and controlled by a federally regulated depository institution). The guidance also recommends third-party risk management considerations for banks applicable to their relationships with AMCs. For example, the guidance recommends that bank management conduct sufficient due diligence to confirm that an AMC appropriately identifies transactions requiring a state certified or licensed appraiser if the bank relies on the AMC to determine whether a state certified or licensed appraiser is required for each transaction. The guidance also explains that, when no registered AMC is available, a bank may use an individual appraiser, a staff appraiser employed by the bank, a smaller AMC that has a panel with fewer than 15 appraisers in any state and fewer than 25 appraisers nationally in a given year (and is therefore not subject to the registration requirements), or a federally regulated AMC. Click here for a copy of the OCC’s guidance on registered AMCs.

Nutter Notes: Under Section 1473 of the Dodd–Frank Act, states are not required to establish an AMC registration and supervision program. In a state that does not have an AMC registration and supervision program, AMCs are prohibited from providing appraisal management services for most real-estate related financial transactions involving a federally regulated depository institution. However, the AMC registration requirement does not apply to an AMC that oversees a panel of 15 or fewer appraisers in a single state and fewer than 25 appraisers nationally in a given year. An AMC that is owned and controlled by an insured depository institution and regulated by the OCC, Federal Reserve, or FDIC is not subject to the registration requirement. The OCC’s guidance advises that several states may not offer the electronic capability to verify the registration status of AMCs. In these cases, the OCC recommends that bank management request evidence of registration directly from the AMC. In addition, the Appraisal Subcommittee (ASC) of the FFIEC is required to maintain an AMC national registry that includes AMCs that are registered with and subject to supervision by a state appraiser certifying and licensing agency or are federally regulated. According to the OCC’s guidance, an AMC that is listed on the ASC’s national AMC registry can be presumed to have met the AMC registration requirement.

3. CFPB Announces New Policies to Promote Innovation in Consumer Financial Services

The CFPB has released three new policies related to innovation and regulatory compliance: a revised No-Action Letter (NAL) Policy, Trial Disclosure Program (TDP) Policy, and Compliance Assistance Sandbox (CAS) Policy. The revised NAL policy issued on September 10 makes a number of changes to the CFPB’s 2016 NAL Policy to include, among other things, a more streamlined review process focusing on the consumer benefits and risks of the product or service in question. The new TDP Policy issued on September 10 allows banks and other consumer financial services providers seeking to improve consumer disclosures to conduct in-market testing of alternative disclosures for a limited time with the permission of the CFPB. The CAS Policy issued on September 10 enables testing of a new financial product or service where there is uncertainty about the permissibility of the product or service. Under the CAS policy, a consumer financial services provider may apply to the CFPB for a safe harbor from certain consumer protection liability for specified conduct during a testing period. The CFPB will evaluate the product or service for compliance with relevant law. If approved, an applicant that complies in good faith with the terms of the approval may receive protection from liability under the Truth in Lending Act, the Electronic Fund Transfer Act, and the Equal Credit Opportunity Act with respect to the new financial product or service during the testing period. Click here for a copy of the revised NAL Policy, click here for a copy of the TDP Policy, and click here for a copy of the CAS Policy.

Nutter Notes: On September 10, the CFPB also announced the launch of the American Consumer Financial Innovation Network (“ACFIN”) to enhance coordination among federal and state regulators in facilitating financial innovation. The CFPB said that it has invited all state regulators to join ACFIN. The initial members of ACFIN are the Attorneys General of Alabama, Arizona, Georgia, Indiana, South Carolina, Tennessee, and Utah. According to the ACFIN charter, its objectives include coordination among members to benefit consumers by facilitating innovation that enhances competition, consumer access, or financial inclusion. The ACFIN also seeks to minimize unnecessary regulatory burdens, bolster regulatory certainty for innovative consumer financial products and services, and help ensure that markets for consumer financial products and services are free from fraud, discrimination, and deceptive practices. To accomplish these objectives, the ACFIN charter provides that members will cooperate with each other through, among other things, coordinating innovation-related policies, procedures, and activities, with the opportunity to also coordinate on no-action letters or sandbox trials. The ACFIN charter also contemplates that members will share information related to innovation in markets for consumer financial products and services, including technical expertise, market intelligence, and best practices.

4. House Approves Bill to Provide Safe Harbor for Banks that Service Marijuana Businesses

The U.S. House of Representatives voted to approve H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 with bipartisan support by a vote of 321-103. The bill approved by the House on September 25, if it became law, would create protections for depository institutions that provide financial services to a “cannabis-related legitimate business” operating in compliance with applicable state laws. The Senate is expected to consider a similar measure. The bill defines “cannabis-related legitimate business” to include a manufacturer, producer, or other person or company that participates in the cultivation, production, manufacture, sale, transport, display, dispensing, distribution, or purchase of marijuana or marijuana products pursuant to state law. The bill would prevent any federal banking agency from prohibiting a depository institution (or its service providers) from, or penalizing a depository institution (or its service providers) for, providing a financial service to a marijuana business or a service provider of a marijuana business that operates in compliance with state law. The bill is supported by the major national banking and credit union trade associations and a group of 50 state bankers associations. Click here for a copy of the current text of the bill.

Nutter Notes: The SAFE Banking Act of 2019 was introduced by Representative Ed Perlmutter of Colorado and is co-sponsored by over 200 representatives from both parties. The bill would not affect the status of cannabis or marijuana as an illegal substance under the Federal Controlled Substances Act. Therefore, even if the bill becomes law, the cultivation, distribution, and possession of marijuana would remain criminal under federal law, and all proceeds of such activities would remain illicit funds under federal law. The bill would amend the Bank Secrecy Act to require FinCEN to issue guidance on suspicious activity reporting (“SAR”) related to a cannabis-related legitimate business or service provider. The bill would require that any such SAR must comply with the guidance, and that the guidance be consistent with the purpose and intent of the SAFE Banking Act of 2019 to “not significantly inhibit the provision of financial services to a cannabis-related legitimate business or service provider in” a state or other political subdivision of the U.S. in which marijuana-related business has been legalized.

5. Other Developments: Examination Surveys and Deposit Insurance Applications

  • FDIC Office of the Ombudsman Will Take Over Post-Examination Surveys

The FDIC announced on September 19 that the Office of the Ombudsman will now be administering the post-examination survey process. The Ombudsman is independent of the supervisory process, reports directly to the FDIC Chairman’s office, and is a confidential resource for banks. The FDIC said that the change is meant to ensure confidentiality of survey responses, promote additional candid feedback, and improve response rates.

Nutter Notes: The Ombudsman will assume responsibility for soliciting post-examination survey responses effective October 1, 2019. The Ombudsman will send notice that the survey will accompany a Report of Examination and will provide reminders to encourage participation in the survey. The Ombudsman will also serve as the contact point for banks regarding the survey and follow-up requests. Click here for a copy of the FDIC’s announcement and a copy of the current survey questions for each exam type.

  • FDIC Issues Guidance on Applications for Deposit Insurance

The FDIC issued guidance in the form of supplemental questions and answers (“Supplemental Q&As”) to help organizing groups develop applications for deposit insurance. The Supplemental Q&As note that applications for deposit insurance do not need to identify a specific physical location (i.e., an address) for the proposed institution’s main office at the time of submission. The Supplemental Q&As also clarify that, while the proposed chief executive officer is to be identified at the time of filing, other senior executive officers may be identified later in the process.

Nutter Notes: The new Supplemental Q&As supplement the FDIC’s Statement of Policy on Applications for Deposit Insurance, issued in 1998. For organizing groups that have not yet identified the specific address of the main office at the time of filing, the Supplemental Q&As instruct the applicants to reasonably describe the anticipated physical location so that the FDIC and other interested parties can understand the general location and geographic market of the proposed institution. Click here for a copy of the Supplemental Q&As.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Nutter McClennen & Fish LLP | Attorney Advertising

Written by:

Nutter McClennen & Fish LLP

Nutter McClennen & Fish LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.