News & Analysis as of

Federal Pilot Programs Advisory Opinions

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

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

BCLP

CFPB Rolls Out Pilot Program Offering Advisory Opinions

BCLP on

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

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

Baker Donelson

Real-Time EMR Interface Program to Reduce Readmissions Finds Favor in OIG Advisory Opinion 17-07

Baker Donelson on

A pilot program that could improve the efficacy of medication therapy management (MTM) services among Medicare Advantage (MA) beneficiaries would present minimal risk to federal health care programs and patients, according to...more

Baker Donelson

Real-Time EMR Interface Program to Reduce Readmissions Finds Favor in OIG Advisory Opinion 17-07

Baker Donelson on

A pilot program that could improve the efficacy of medication therapy management (MTM) services among Medicare Advantage (MA) beneficiaries would present minimal risk to federal health care programs and patients, according to...more

Robinson+Cole Health Law Diagnosis

OIG Advisory Opinion Allows Pilot Collaborative Program Proposed by Pharmaceutical Manufacturer for Medication Therapy Management...

On December 11, 2017, the Health and Human Services Office of Inspector General (OIG) posted a favorable Advisory Opinion, permitting a proposed pilot Program involving a collaboration between a pharmaceutical manufacturer...more

Morrison & Foerster LLP

ITC Pilot Program to Expedite Rulings on Whether Exclusion Orders Cover Redesigns and New Products

On February 24, 2015, the ITC announced a new pilot program to decide whether redesigns or new products are covered by ITC exclusion orders. The announced goal of the program is to test the use of expedited procedures for the...more

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