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Policies and Procedures Settlement Disclosure Requirements

Foley & Lardner LLP

SEC Settlement Highlights Importance of Proper Disclosure Requirements for Private Fund Managers

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On January 10, 2025, the Securities and Exchange Commission (SEC) settled charges against two fund managers (collectively the “Fund Managers”) and their sole owner, chief executive office, chief compliance office, and founder...more

Health Care Compliance Association (HCCA)

In This Month’s E-News: November 2024

On the heels of a $7.6 million payment by Cleveland Clinic to settle allegations of False Claims Act (FCA) violations and unallowable sharing of passwords, Michael Lauer, NIH deputy director for extramural research, penned a...more

Seward & Kissel LLP

SEC Settles Charges Against Private-Equity Firm for Alleged Disclosure Policy Failures

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Quick Take: The SEC settled charges against a private-equity fund Adviser for failing to maintain and enforce policies and procedures reasonably designed to prevent the misuse of material nonpublic information (MNPI) and to...more

BCLP

SEC penalizes company with good disclosures for insufficient controls

BCLP on

What happened? In a recent settlement order, the SEC charged Activision Blizzard with failing to maintain adequate disclosure controls and procedures. Notably, the SEC did not claim that the company’s SEC filings were...more

Akerman LLP - Health Law Rx

Healthcare Providers Must Remember HIPAA Before Responding to Online Reviews

The latest HIPAA resolution agreement by the U.S. Department of Health and Human Services Office for Civil Rights (OCR) is a reminder that healthcare providers must take the high road when responding to unflattering online...more

Ballard Spahr LLP

OCR Announces $10,000 Settlement for Disclosure of Patients’ PHI through Social Media

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The Office for Civil Rights (OCR) at the Department of Health and Human Services announced it reached a settlement with Elite Dental Associates of Dallas (Elite) to resolve a complaint alleging Elite impermissibly disclosed a...more

Foley & Lardner LLP

Recent MCDC Settlements Provide Guidance Concerning Scope of Materiality in Continuing Disclosure Obligations

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In responding to the Securities and Exchange Commission’s recent Municipalities Continuing Disclosure Cooperation (MCDC) initiative, the unanswered question for many municipalities and broker-dealers was determining whether...more

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