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Reporting Requirements Third-Party Service Provider

K&L Gates LLP

Europe: National Regulators Announce Digital Operational Resilience Act Reporting Windows

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EU national supervisory authorities will collect the Register of Information (ROI) pursuant to the EU’s Digital Operational Resilience Act (DORA) from in scope financial entities in April 2025, with the reference date set as...more

Verrill

The Gag Clause Quandary for Self-Insured Group Health Plans—New FAQ Guidance

Verrill on

The Departments of Labor, Health and Human Services, and the Treasury, with the Office of Personnel Management (the “Departments”) jointly released FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more

Latham & Watkins LLP

UK Regulators Consult on New Reporting Requirements for Operational Incidents and Use of Material Third Parties

Latham & Watkins LLP on

On 13 December 2024, the FCA and the PRA published linked Consultation Papers on operational incident and third-party reporting (FCA CP24/28 and PRA CP17/24). The consultations aim to create a structured framework for...more

A&O Shearman

European Supervisory Authorities Urge Financial Entities to Ensure Timely Compliance with EU Digital Operational Resilience Act

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The European Supervisory Authorities have published a joint statement on the application of the EU Digital Operational Resilience Act. The ESAs emphasise that as DORA does not provide for a transitional period, it is...more

Lippes Mathias LLP

Hospital Administrators – Is Your Hospital Cyber-Secure?

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On October 2, 2024, New York adopted new regulations requiring general hospitals to implement heightened cybersecurity safeguards. General hospitals, as defined in Article 28 of the NY Public Health Law, generally must begin...more

Seyfarth Shaw LLP

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

Seyfarth Shaw LLP on

On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

WilmerHale

Obligations for Deployers, Providers, Importers and Distributors of High-Risk AI Systems in the European Union’s Artificial...

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In this blog post, we will focus on obligations that the European Union’s Artificial Intelligence Act (AI Act) sets for deployers, providers, importers and distributors regarding high-risk AI systems....more

Foley & Lardner LLP

SEC Tightens Cybersecurity Requirements with Regulation S-P Amendments

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Share on Twitter Print Share by Email Share Back to top “The basic idea for covered firms is if you’ve got a breach, then you’ve got to notify. That’s good for investors.” Those were among the remarks that U.S. Securities and...more

Dorsey & Whitney LLP

CTA Compliance Obligations for CTA Participants: Reporting Companies, Beneficial Owners, and Third-Party Preparers

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In an evolving (and somewhat disjointed) process, FinCEN has been providing guidance to persons and entities that are responsible for filing required beneficial ownership information (“BOI”) reports to FinCEN, as well as to...more

Mitratech Holdings, Inc

Compliance Down Under: Understanding Australian Regulation CPS 230

The Australian Prudential Regulation Authority (APRA) released Prudential Standard CPS 230 in March 2017. At a glance, the regulation aims to strengthen the cybersecurity resilience and operational risk management of the...more

Foodman CPAs & Advisors

El Identificador FinCEN

El 29 de septiembre del 2023, FinCEN actualizó las preguntas frecuentes (“FAQs”) sobre los Reportes de Información sobre los Beneficiarios Reales (“BOI”), incluyendo orientación sobre el Identificador FinCEN. Las preguntas...more

Foodman CPAs & Advisors

The FinCEN Identifier

On September 29, 2023, FinCEN updated the FAQs regarding Beneficial Ownership Information (BOI) Reporting, including guidance on the FinCEN identifier. The FinCEN’s BOI FAQs work in tandem with the FinCEN’s BOI Small...more

A&O Shearman

UK sanctions systems and controls: lessons learnt

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The UK Financial Conduct Authority (FCA) has assessed the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors and summarised its findings of good and poor practice. Acknowledging...more

Bond Schoeneck & King PLLC

U.S. Department of Education Issues Dear Colleague Letter on May 16, 2023 to Update Earlier Guidance on Third-Party Servicers

On Feb. 15, 2023, the U.S. Department of Education (Department) surprised the higher education community with a Dear Colleague Letter (DCL GEN-23-03) that sets forth new guidance on third-party servicers with whom...more

Husch Blackwell LLP

Update: U.S. Department of Education Third-Party Servicer Guidance - 4/14/2023

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UPDATE: On April 11, the Department of Education (Department) published a blog post updating the latest Third-Party Services (TPS) Dear Colleague Letter (DCL) which was published on February 15, 2023 (updated February 28,...more

Husch Blackwell LLP

Update: U.S. Department of Education Third-Party Servicer Guidance

Husch Blackwell LLP on

UPDATE: On February 28, 2023, the Department updated the Dear Colleague Letter issued February 15, 2023 to establish a future effective date for the guidance, extend the public comment period, and extend the reporting...more

Husch Blackwell LLP

Department of Education Expands Interpretation of "Third-Party Servicer" Definition (and Announces Incentive Compensation Review)

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Wednesday’s U.S. Department of Education Dear Colleague Letter announces an expanded Department interpretation of the definition of Third-Party Servicer to include a new array of vendors providing student recruiting and...more

Foley & Lardner LLP

Price Transparency and CAA Checklist for Plan Service Providers

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Group health plans must comply with several new requirements set forth by the Consolidated Appropriations Act of 2021 (CAA) and the Transparency in Coverage regulations (TiC Regulations) under the Affordable Care Act (ACA). ...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

EEOC Makes Major Revisions to 2021 EEO-1 Filing Procedures for Third-Party Human Resource Organizations

The U.S. Equal Employment Opportunity Commission (EEOC) recently announced its effort to modernize the agency’s EEO data collection by revising the procedures for professional employer organizations (PEOs), administrative...more

Foley & Lardner LLP

New Prescription Drug and Health Care Spending Reporting Requirements from a Carrier and Plan Service Provider Perspective

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Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...more

Hinshaw & Culbertson - Employment Law...

OSHA Guidance on Preparing to Return to Work Includes Recommendations for White Collar Businesses

The Occupational Health and Safety Act (the OHS) was signed into law in 1970 and established the Occupational Health and Safety Administration (OSHA), as part of the U.S. Department of Labor. Under the so-called "general...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2020

The FDIC and OCC have issued new guidance for banks on heightened cybersecurity risks facing the financial services industry because of increased geopolitical tensions and threats of aggression. The guidance published on...more

Perkins Coie

Dying and Private Keys

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Cryptocurrency owners must face death—be it their own, or that of anyone else with custody of the owner’s cryptocurrency or other digital assets. We received a stark reminder of this when the Canadian exchange QuadrigaCX...more

Bradley Arant Boult Cummings LLP

New Year, New Data Security Requirement: South Carolina Adopts New Data Security Law

On January 1st, South Carolina became the first state to adopt the model insurance data security law requiring certain insurance licensees to investigate and report cybersecurity events in the state of South Carolina. The law...more

Mintz - Privacy & Cybersecurity Viewpoints

Uber and FTC Arrive at Settlement: Extensive Monitoring, but no FTC Fines Ahead

Recently, the Federal Trade Commission (“FTC”) announced that it has finalized its expanded settlement with ride-haling giant, Uber Technologies, Inc. (“Uber”) related to two major data breach incidents. The initial breach...more

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