News & Analysis as of

Data Collection Good Faith

Morrison & Foerster LLP

Top 5 SEC Developments (October 2023)

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Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month we examine: • Fraud and internal control failure charges against...more

Fisher Phillips

Brazil Publishes Data Protection Sanctions: 3 Steps Your Company Should Take to Avoid Problems

Fisher Phillips on

Brazil’s data protection authority recently published regulations that could lead businesses and employers that violate the country’s data privacy laws to be punished with administrative penalties – adding yet more incentive...more

Foley & Lardner LLP

RxDC Reporting Relief for Plans, Issuers, and Plan Service Providers

Foley & Lardner LLP on

On December 23, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) provided welcome relief in the form of an FAQ regarding the Prescription Drug Data Collection (RxDC)...more

Verrill

A Last-Minute Gift – Prescription Drug Reporting Grace Period and Good Faith Relief

Verrill on

In a move akin to last-minute gift-giving, the Departments of Labor, Health and Human Services, and the Treasury (the “Departments”) released FAQ 56 on December 23, 2022, which provides relief regarding the Prescription Drug...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute UPDATE: RxDC Reporting Relief

On December 23, 2022, FAQs were released outlining late-breaking RxDC Reporting Relief. Of note - 1. For the 2020 and 2021 data submissions that are due by December 27, 2022, the Departments will not take enforcement...more

Farrell Fritz, P.C.

Blink, And I’m Gone: E-Discovery Challenges And Considerations With Ephemeral Messaging

Farrell Fritz, P.C. on

There is an ever-increasing volume of data generated by businesses. In an effort to reduce storage costs and ameliorate privacy concerns, companies have embraced ephemeral, or self-destructing messaging. And, while...more

Sheppard Mullin Richter & Hampton LLP

US Breach Laws Are Coming: Vermont

On January 1, 2019 Vermont’s breach notice law will include obligations specific to data brokers. A “data broker” is defined as a business that “knowingly collects and sells or licenses to third parties the brokered personal...more

Ballard Spahr LLP

CFPB, other agencies announce good faith efforts approach to revised HMDA rule enforcement; CFPB to engage in HMDA rulemaking to...

Ballard Spahr LLP on

The CFPB has announced that with regard to the collection in 2018 of the expanded data fields under the revised Home Mortgage Disclosure Act (HMDA) rules, the CFPB does not intend to require data resubmission unless data...more

Baker Donelson

Recent CFPB Report to Congress

Baker Donelson on

On November 12, 2013, Richard Cordray, Director of the CFPB, appeared at the hearing of the Senate Banking, Housing and Urban Development Committee to discuss the CFPB's Annual Report to Congress. During the hearing, Senators...more

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