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Policies and Procedures

Starbucks and Lessons for the Compliance Practitioner in Risk Management

by Thomas Fox on

Recently Starbucks generated extremely negative news for having Philadelphia police arrest two persons who were waiting for a third person for a meeting. I want to use this most recent black eye for Starbucks and an earlier...more

FERC Issues NOI on Natural Gas Pipeline Siting Issues

by Holland & Knight LLP on

At its April 19, 2018 open meeting, the Federal Energy Regulatory Commission (FERC) unanimously voted to open a new Notice of Inquiry (NOI) seeking input on whether, and if so how, it should update its existing policies and...more

SEC Staff Issues Risk Alert on the Six Most Frequent Fee and Expense Compliance Issues

by Proskauer Rose LLP on

On April 12, 2018, the SEC's Office of Compliance Inspections and Examinations ("OCIE") issued a risk alert listing the most common compliance issues concerning fees and expenses charged by SEC-registered investment advisers....more

Drop in Warning Letters for Medical Devices Raises Interesting Questions About the Industry

In 2017, FDA issued only 44 Warning Letters to medical device establishments. Of those, 11 were related to pre-market issues, which include investigational device exemption violations or lack of approval or clearance. Only 33...more

Bid Protests of State Procurements in the DMV (D.C., Maryland, and Virginia) Part 2 of 3 – D.C.

by Miles & Stockbridge P.C. on

For the second post in our three part series regarding state-level bid protests in the DMV, we turn our attention to the District of Columbia. In our first post we discussed the authorities and procedures for Maryland...more

FFIEC Highlights Cyber Insurance for Financial Institutions

The Federal Financial Institutions Examination Council (FFIEC) has issued a joint statement emphasizing the need for lenders and servicers to include cyber insurance in their risk management program. Although the FFIEC did...more

SDE Issues New Guidelines for IEEs and In-School Observations

by Shipman & Goodwin LLP on

On March 27, 2018, the Connecticut State Department of Education (SDE) issued the long-awaited and much-anticipated Guidelines Regarding Independent Educational Evaluations at Public Expense and In-School Observations. These...more

Making Sure the Good Deed Goes Unpunished: Navigating Director and Officer Liability Insurance for Community Associations

by Ward and Smith, P.A. on

A community or property owner association ("Association") acts through board members and officers who are volunteers and are generally willing to serve because they care about their communities. But in this day and age,...more

Weekly Update Newsletter - April 2018

by PilieroMazza PLLC on

DEPARTMENT OF LABOR - US Department of Labor reinstates Wage and Hour opinion letters - The U.S. Department of Labor will reinstate the issuance of opinion letters, U.S. Secretary of Labor Alexander Acosta announced on...more

Massachusetts Case Against Equifax Survives Motion to Dismiss

by Goodwin on

On April 2, 2018, the Superior Court of Suffolk County, Massachusetts denied Equifax, Inc.’s motion to dismiss the Commonwealth’s case against it related to the company’s widely publicized 2017 data breach. Although the...more

Best Practice Tips for the Law Firm Records Management Professional

by Epiq on

Law firms are in the information business. Information is a critical operational asset for firms, and is effectively the primary product. With the dramatic explosion of the volume of information and the risks inherent in...more

Deeming the Tracking of a Debtor’s Every Move “Impractical,” District Court Finds a Bona Fide Error and Dismisses FDCPA Action...

A district court has dismissed an FDCPA action based on a bona fide error after reviewing the collection firm’s extensive pre-suit procedures and determining they were reasonably calculated to avoid any errors. Guynn v....more

ISS Launches New Online Communications Portal, Updates U.S. Voting Policy FAQs

New ISS Help Center - On April 9, 2018, Institutional Shareholder Services Inc. (ISS) launched a new online communications portal, the ISS Help Center, to provide a simplified interface for submitting questions to ISS...more

New York State Employers Face Significant New Sexual Harassment Laws

by Fisher Phillips on

Employers operating in New York will soon face a raft of new sexual harassment laws. The state budget bill for the 2019 fiscal year approved by the New York State Legislature on March 31 and signed into law by Governor Andrew...more

Bid Protests of State Procurements in the DMV (D.C., Maryland, and Virginia) Part 1 of 3 - Maryland

by Miles & Stockbridge P.C. on

This is part 1 of a 3 part series discussing state-level bid protests in the DMV. For a contractor who just expended significant time and money to bid on a DMV state-level government contract, only to watch the award...more

How to Mitigate Inappropriate Watercooler Talk in the Current Sexually Salacious News Environment

by Foley & Lardner LLP on

Regardless of your political leaning, it is fair to say that national headlines over the past few weeks have been dominated by sexually charged topics. For instance, a porn star known as Stormy Daniels recently gave an...more

Smokestack Emissions Testing and Reporting: U.S. Environmental Protection Agency Office of Inspector General April 10th Project...

The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued an April 10th Project Notification that it plans to: . . . begin preliminary research for an audit of the EPA’s oversight...more

SEC Releases Interpretive Guidance on Cybersecurity Risk and Incident Disclosures

by Moore & Van Allen PLLC on

On Feb. 22, 2018, the Securities and Exchange Commission (SEC) issued its first interpretive guidance since October 2011 on public companies’ cybersecurity risk and incident disclosure obligations. ...more

Recognizing the Risks of a Malicious Insider

by Ward PLLC on

Although we often hear the most about hackers, mostly because it allows media to use the standard “faceless guy in a hoodie” images, black hats are not the only cause of data breaches. In fact, one of the biggest risks to...more

Podcast - Risk Mitigation & Management: Bringing a Compliance Program to Life

by Ropes & Gray LLP on

[co-speaker: Hui Chen, former Department of Justice Compliance Counsel] Compliance programs are difficult to design, and implementing and enforcing policies and procedures is challenging, especially in complex, global...more

What HIPAA Policies are Required for a Health Care Provider?

by Ruder Ware on

We are often asked to advise clients regarding the scope and content of Health Insurance Portability and Accountability (HIPAA) policies and procedures that are required to be maintained. HIPAA clearly requires health care...more

ISS Updates Its US Proxy Voting Research Procedures & Policies FAQs

by White & Case LLP on

On March 29, 2018, Institutional Investor Services ("ISS") updated its US Proxy Voting Research Procedures & Policies frequently asked questions ("FAQs")1 . While the 2018 US proxy season is well underway, these updated FAQs...more

Medicaid Drug Rebate Agreements: Changes Require Immediate Action By Pharmaceutical Manufacturers

by Foley & Lardner LLP on

For the first time since the enactment of the Medicaid Drug Rebate Program (MDRP), the Centers for Medicare and Medicaid Services (CMS) revised the National Medicaid Drug Rebate Agreement (NDRA) entered into between drug...more

K&L Gates Triage: Sexual Harassment in Healthcare: #MeToo and Beyond

by K&L Gates LLP on

In this episode, Bridget Blinn-Spears discusses sexual harassment issues for health care employers in the wake of the #MeToo movement. While the law in this area has been established for decades, there continues to be a high...more

When Does a HIPAA Breach Exist?

by Ruder Ware on

Conducting HIPAA Breach Risk Assessments - The HIPAA rules relating to assessment of potential patient confidentiality breaches were changed in 2013. Specifically, on January 17, 2013, the Office of Civil Rights released...more

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Cybersecurity

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