Episode 365 -- Four Sanctions Cases Everyone Should Know
UPIC Audits
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The Public Company Accounting Oversight Board (PCAOB) delayed the adoption of a final rule with respect to its June 2023 proposal (Proposal) to increase auditors’ responsibility to evaluate and disclose a public company’s...more
On February 6, 2024, the New York State Department of Financial Services (“DFS”) released “pre-proposed” consolidated rulemaking related to the business practices of Pharmacy Benefit Managers (“PBMs”) licensed to operate in...more
The Background: The California Privacy Protection Agency board ("CPPA" or "Board") is in the process of issuing new regulations as authorized under the California Privacy Rights Act. These three sets of proposed regulations...more
As we have detailed previously, 2023 was a landmark year for privacy law, featuring numerous developments at the federal, state and international levels, ranging from newly enacted statutes to massive regulatory enforcement...more
The California Privacy Protection Agency (“CPPA”) issued and discussed draft regulations on Cybersecurity Audits and Risk Assessments late in the summer. The CPPA Board plans to discuss the draft regulations at its upcoming...more
On November 1, 2023, the industry groups (the Petitioners) challenging the new Private Fund Adviser Rules filed in the US Court of Appeals for the Fifth Circuit their opening brief (the Brief) setting forth their legal...more
On August 29, 2023, the California Privacy Protection Agency (CPPA) Board unveiled Draft Regulations on Risk Assessment and Cybersecurity Audit. The CPPA Board announced that the formal rulemaking process will begin soon,...more
The California Privacy Protection Agency (CPPA) has released its agenda for the September 8 board meeting, which includes (among other topics) presentation of a draft Cybersecurity Audit Regulation and a draft Risk Assessment...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
The CPPA kicked off a first round of rulemaking in May 2022 and finalized that set of rules in March of this year. At the latest California Privacy Protection Agency (CPPA) meeting, the CPRA Rules Subcommittee (Rules...more
While the U.S. Securities and Exchange Commission (“SEC”) has been working on its climate disclosure rulemaking for the past 15 months, the California legislature may end up beating it to the punch. The SEC first announced...more
On Friday, March 3, 2023, the California Privacy Protection Agency (CPPA) held a public board meeting. Though the meeting focused primarily on the Agency’s budget and various administrative issues (e.g., subcommittee...more
It has been a bustling fall for the California Privacy Protection Agency (CPPA or Agency). In the spirit of the upcoming holiday season, the Agency gifted us not one but two rounds of proposed modifications to the regulations...more
While the DoD charts a path forward on CMMC, the USG is emphasizing the need to comply with existing cyber obligations in government contracts and taking steps to enforce compliance with those obligations. The June 16 Memo...more
Automated and algorithmic decision-making tools have become run-of-the-mill in everything from loan and apartment applications to employment searches and university acceptances. Such tools provide increased efficiency,...more
On January 6, 2020, Governor Ned Lamont signed bipartisan legislation addressing rates of pay for restaurant workers. The Governor vetoed a previous version of the bill which would have applied retroactively and effectively...more
New Procedures: Old Problems – Don’t get caught off guard! On February 26, the Media Bureau issued its first Equal Employment Opportunity (“EEO”) audit of 2018 to randomly selected radio and television stations. There are...more
In This Issue: - Sales Factor Sourcing of Services & Intangibles - Nonresident Limited Partners Liable for Personal Income Tax - PA Appeal Systems Changes Update - Personal Responsibility for...more
On August 6, 2014, the Office of Federal Contract Compliance Programs (“OFCCP”) released a Notice of Proposed Rulemaking requiring federal contractors and subcontractors with 100 or more employees to submit an annual equal...more
The Office of the Chief Auditor of the PCAOB issued an updated standard-setting agenda, providing the expected timing and key milestones for various PCAOB rulemaking projects. Some of the highlights from the agenda, which was...more