News & Analysis as of

Risk Management Comment Period

Eversheds Sutherland (US) LLP

The CFTC issues requests for comments on 24/7 trading and perpetual derivatives contracts

On April 21, 2025, the Commodity Futures Trading Commission (CFTC) Divisions of Market Oversight, Clearing and Risk, and Market Participants issued two Requests for Comment (RFCs) on 24/7 trading and clearing of derivatives...more

Sheppard Mullin Richter & Hampton LLP

FedRAMP 20x – Update on Significant Change Process and Assessment Scope Standards

Last month, the federal government announced a major overhaul of the Federal Risk and Authorization Management Program (“FedRAMP”) called “FedRAMP 20x”. FedRAMP 20x is moving forward fast – with new authorizations, community...more

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

New Mexico Is the Next State With a Proposed Heat Illness Rule

New Mexico is the next state to propose a heat exposure rule for workers. The New Mexico Environment Department has proposed a rule aimed at preventing heat-related illnesses and injuries in the workplace....more

A&O Shearman

SRB consultation on operational guidance on resolvability testing for banks

A&O Shearman on

The Single Resolution Board (SRB) has opened a consultation on its operational guidance on resolvability testing for banks under the SRB's remit. It aims to ensure that European banks are regularly testing their capabilities...more

A&O Shearman

IOSCO publishes consultation report on AI in capital markets

A&O Shearman on

The International Organization of Securities Commissions (IOSCO) has published a consultation report on the use cases, risks and challenges of AI in capital markets. The report, which is based on feedback from IOSCO's members...more

Goldberg Segalla

Update RE: EPA’s Proposed PFAS Rule Comment Period

Goldberg Segalla on

In 2024, the EPA proposed a PFAS rule with a January 17, 2025, comment deadline in response to questions from the industry regarding the effective date of supplier notifications for mixtures or trade name products containing...more

A&O Shearman

Basel Committee on Banking Supervision consults on amendments to principles for the management of credit risk

A&O Shearman on

The Basel Committee on Banking Supervision (Basel Committee) published a consultative document on updating the principles for the management of credit risk. The principles, first issued in October 2000, provide guidelines for...more

Esquire Deposition Solutions, LLC

New Jersey Weighs New Duty of Technology Competence

New Jersey appears poised to become the next state to explicitly add a duty of technology competence to its professional code of ethics. Proposed revisions to the New Jersey Rules of Professional Conduct would, if adopted,...more

White & Case LLP

What’s New – FAR Council Publishes Proposed Rules Concerning CUI and OCIs

White & Case LLP on

On January 15, 2025, the Federal Acquisition Regulatory Council (FAR Council) proposed two significant rule changes that could reshape compliance obligations for government contractors: one establishing standardized...more

Bergeson & Campbell, P.C.

EPA Extends Comment Period on Draft TSCA Risk Evaluation for 1,3-Butadiene

The U.S. Environmental Protection Agency (EPA) announced on January 31, 2025, that it is extending the public comment period on the draft risk evaluation for 1,3-butadiene under the Toxic Substances Control Act (TSCA). 90...more

McDermott+

To Comment or Not to Comment: Looking at the Biden Administration’s HIPAA Cybersecurity Proposed Reg

McDermott+ on

One of the Biden Administration’s last healthcare regs was a proposed rule that, if finalized, would make significant changes to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Security Rule to...more

Sheppard Mullin Richter & Hampton LLP

FedRAMP Releases New Draft Authorization Boundary Guidance

Over the last few years, the Federal Risk and Authorization Management Program (“FedRAMP”) Program Management Office (“PMO”) has released two draft guidance documents related to defining the applicable boundary for security...more

DLA Piper

Key Takeaways from FDA’s Draft Guidance on Use of AI in Drug and Biological Life Cycle

DLA Piper on

The US Food and Drug Administration (FDA) recently issued its draft guidance, Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products, on January 6, 2025. ...more

Faegre Drinker Biddle & Reath LLP

Proposed HIPAA Security Rule Updates — Implications for Covered Entities and Their Information Security Programs

On January 6, 2025, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) published a notice of proposed rulemaking (Proposed Rule) updating the Health Insurance Portability and...more

Fenwick & West LLP

FDA Issues Draft Guidances on AI in Medical Devices, Drug Development: What Manufacturers and Sponsors Need to Know

Fenwick & West LLP on

The Food and Drug Administration (FDA) has recently released two draft guidance documents (Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations and...more

Bergeson & Campbell, P.C.

EPA Releases Draft Risk Assessment of PFOA and PFOS in Biosolids, Will Hold Webinar on January 15, 2025

The U.S. Environmental Protection Agency (EPA) announced on January 14, 2025, a draft risk assessment of the potential human health risks associated with the presence of perfluorooctanoic acid (PFOA) and perfluorooctane...more

Ballard Spahr LLP

HHS Proposes Significant Updates to HIPAA Security Rule

Ballard Spahr LLP on

On January 6, 2025, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) published a Notice of Proposed Rulemaking (“NPRM”) to amend the Health Insurance Portability and Accountability Act...more

Wiley Rein LLP

As D2D Deployment Increases, NTIA Seeks Comment on Potential Risks to GPS

Wiley Rein LLP on

The National Telecommunications and Information Administration (NTIA) has published a Notice and Request for Comment (RFC) on the potential impact of the increasing deployment of satellite-enabled direct-to-device (D2D)...more

Fisher Phillips

Proposed Updates to HIPAA Security Rule Would Require Entities to Adopt Enhanced Cybersecurity Measures

Fisher Phillips on

The HIPAA Security Rule may soon undergo a big overhaul that would better defend healthcare data from cybersecurity threats – and require much more from covered entities when it comes to establishing and maintaining defenses....more

Hogan Lovells

TSA rule would require cyber risk management for railroads, buses, and pipeline operators

Hogan Lovells on

On November 6, 2024, the Transportation Security Administration (TSA) published a Notice of Proposed Rulemaking (NPRM) that would mandate cyber risk management and reporting requirements for certain surface transportation...more

Jones Day

TSA Releases Proposed Rule to Enhance Pipeline and Railroad Cyber Risk Management

Jones Day on

The Transportation Security Administration's ("TSA") proposed rule would require owners and operators of certain pipeline, freight railroad, passenger railroad, rail transit, and over-the-road bus ("OTRB") systems to...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other...

Ballard Spahr LLP on

On July 25, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a “Joint Statement on Banks’...more

Fenwick & West LLP

FDIC Proposes More Oversight on Custodial Deposit Accounts

Fenwick & West LLP on

On September 17, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would significantly impact the risk management and oversight requirements for bank-fintech arrangements. This proposal comes in...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

Ballard Spahr LLP on

The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Venable LLP

Federal Banking Agencies Highlight Bank-Fintech Partnership Risks and Invite Comment

Venable LLP on

On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more

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