News & Analysis as of

Advisory Opinions

Ary Rosenbaum

I’ve seen how this story played out

Ary Rosenbaum on

As everyone is gearing for the January 1, 2021 implementation of pooled employer plans (PEPs), I keep on insisting that this won’t be the game-changer that everyone hopes. I think PEPs are a great idea, it finally...more

Weiner Brodsky Kider PC

DOJ Issues Advisory Opinion on Foreign Corrupt Practices Act

The DOJ recently issued an opinion regarding the Foreign Corrupt Practices Act (FCPA), stating that it would not intend to bring an FCPA enforcement action based upon a payment of a fee to a subsidiary of a foreign investment...more

Shearman & Sterling LLP

DOJ Issues FCPA Opinion Procedure Approving Legitimate Payments To Government Instrumentalities

On August 14, 2020, the U.S. Department of Justice (“DOJ”) released its first Foreign Corrupt Practices Act (“FCPA”) Opinion (the “August 14 Opinion”) in six years, in response to a request from a multinational company...more

Eversheds Sutherland (US) LLP

The DOJ issues its first FCPA advisory opinion after six years of silence

On August 14, 2020, the US Department of Justice (the DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years, which relayed that it did not intend to pursue an enforcement action...more

Arent Fox

Investigations Newsletter: DOJ Issues First FCPA Advisory Opinion Since 2014

Arent Fox on

DOJ Issues First FCPA Advisory Opinion Since 2014 - On August 14, the DOJ issued its first advisory opinion on the Foreign Corrupt Practices Act (FCPA) in six years. The DOJ’s opinion release process allows companies to...more

Weiner Brodsky Kider PC

FinCEN Advisory FIN-2020-A005 Alerts Financial Institutions to Cybercrimes Exploiting COVID-19 Pandemic

A recent FinCEN Advisory (FIN-2020-A005) on cybercrime and cyber-enabled crime exploiting the COVID-19 Pandemic alerts financial institutions to indicators of potential fraudulent schemes, malicious cyber activity and scams,...more

McDermott Will & Emery

DOJ Issues Long-Awaited FCPA Advisory Opinion

McDermott Will & Emery on

On August 14, 2020, for the first time in roughly six years, the US Department of Justice (DOJ) issued an advisory opinion regarding compliance with the Foreign Corrupt Practices Act (FCPA). More than two years ago, former...more

Hinshaw & Culbertson - Lawyers for the...

Florida Bar Advisory Opinion Holds New Jersey Lawyer Working Remotely From Florida Home Does Not Violate Unauthorized Practice of...

Florida State Bar Standing Committee on the Unlicensed Practice of Law Advisory Opinion #2019-4 (August 17, 2020) - Brief Summary - The Florida State Bar Standing Committee on the Unlicensed Practice of Law (Committee)...more

King & Spalding

OIG Issues Advisory Opinion on Arrangement for Charitable Organization to Buy and Forgive Patient Debt from Providers

King & Spalding on

On July 24, 2020, OIG issued an Advisory Opinion (AO), AO 20-04, regarding whether an arrangement where a charitable organization purchases or receives donations of unpaid medical debt from health care providers, and then...more

Baker Ober Health Law

OIG Approves Discount Medical Plan Arrangement with Chiropractors in Advisory Opinion 20-03

Baker Ober Health Law on

In Advisory Opinion 20-03, published July 1, 2020, the Office of Inspector General (OIG) approved an arrangement in which a discount medical plan organization (DMPO) that receives annual membership fees from its members also...more

Goodwin

Issue Twenty-Eight: PTAB Trial Tracker

Goodwin on

The availability of post-grant proceedings at the Patent Trial and Appeal Board (PTAB) has changed the face of patent litigation. This monthly digest is designed to keep you up-to-date by highlighting interesting PTAB,...more

King & Spalding

OIG Issues Advisory Opinion on Discount Medical Plan Organization Arrangement

King & Spalding on

On July 1, 2020, OIG published an advisory opinion regarding a discount medical plan organization (DMPO). A DMPO is not an insurer but contracts with providers who agree to reduce their fees for the DMPO’s members. Under...more

Proskauer - Labor Relations

Update: Federal Judge Amends Prior Order Concerning 2019 Election Rules, Affording Deference to the NLRB, but Appeal to D.C....

In late May, on the eve of the effective date of the NLRB’s sweeping changes to the election process, Judge Ketanji Brown Jackson of the U.S. District Court for the District of Columbia held that certain of the new rules were...more

Mintz - Health Care Viewpoints

OIG Approves Discount Medical Plan Referral Arrangement

On June 26, the Department of Health and Human Services Office of the Inspector General (OIG) issued Advisory Opinion No. 20-03 approving the payment by a discount medical plan organization (DMPO) of a five dollar ($5.00) fee...more

Goodwin

CFPB Pilots Advisory Opinion Program to Address “Regulatory Uncertainty”

Goodwin on

On June 18, 2020, the Consumer Financial Protection Bureau (CFPB) announced the launch of its pilot advisory opinion (AO) program. The CFPB quickly followed this announcement by publishing a procedural rule implementing the...more

Goodwin

Financial Services Weekly Roundup: Code Libor – SEC And OCIE Issue Risk Alert In Preparation Of Libor Discontinuation

Goodwin on

In This Issue. The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert about the scope and content of examinations OCIE plans to conduct of various...more

Weiner Brodsky Kider PC

CFPB Launches New Pilot Advisory Opinion Program

On June 18, 2020, the CFPB announced the launch of a new pilot advisory opinion (AO) program that allows parties that have questions about CFPB regulatory requirements to submit a request for clarification. If the CFPB...more

Hudson Cook, LLP

Clear Skies Ahead? CFPB Launches Pilot Advisory Opinion Program

Hudson Cook, LLP on

On June 22, the CFPB formally launched a pilot advisory opinion (AO) program (Pilot AO Program) that would allow entities seeking to comply with regulatory requirements to submit a request to the Bureau for an opinion where...more

Fox Rothschild LLP

Tri-State Travel Advisory Requires Individuals To Quarantine

Fox Rothschild LLP on

On Wednesday, June 24, 2020, Govs. Cuomo of New York, Murphy of New Jersey and Lamont of Connecticut jointly announced an advisory for travelers arriving in their states from parts of the country hit hard with COVID-19. The...more

Bryan Cave Leighton Paisner

CFPB Rolls Out Pilot Program Offering Advisory Opinions

The devil is in the details. The best intentioned new financial services rules and regulations can present challenges for compliance folks trying to implement the rules into their institutions’ existing systems and...more

Alston & Bird

CFPB Seeks Public Comment on the Advisory Opinion Program

Alston & Bird on

A&B Abstract: On June 18, 2020, the Consumer Financial Protection Bureau (“Bureau”) announced the launch of a pilot advisory opinion program (“Pilot Program”) to publicly address regulatory uncertainty in the Bureau’s...more

Morgan Lewis - All Things FinReg

CFPB Launches Pilot Advisory Opinion Program, Solicits Comment

On June 18, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a procedural rule to launch a new pilot advisory opinion (AO) program to publicly address regulatory uncertainty in the Bureau’s existing...more

Ballard Spahr LLP

CFPB Launches Pilot Advisory Opinion Program

Ballard Spahr LLP on

Having announced earlier this year that it was implementing an advisory opinion (AO) program, the CFPB published a procedural rule in the Federal Register establishing a pilot AO program.  It also published a proposed...more

Skadden, Arps, Slate, Meagher & Flom LLP

Consumer Financial Protection Bureau Launches Advisory Opinion Process

On June 18, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) announced the pilot of a new Advisory Opinion process, offering a potentially useful tool for those seeking guidance on compliance issues. ...more

Latham & Watkins LLP

Green Bond Second Party Opinions: Legal and Practice Considerations

Latham & Watkins LLP on

Annual issuance of “green bonds,” financing instruments connected to business activities with positive environmental effects, have gone from non-existent in 2007 to greater than $250 billion (equivalent) in 2019, using the...more

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

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