News & Analysis as of

Supervision Proposed Rules

K&L Gates LLP

NFA Proposes Guidance on Diligent Supervision of Associated Persons

K&L Gates LLP on

UPDATE: On 1 May 2025, NFA withdrew Interpretive Notice 9083. The guidance remains available on NFA’s website for industry participants’ review....more

Bass, Berry & Sims PLC

CMS Proposes to Extend Virtual Direct Supervision

Bass, Berry & Sims PLC on

On July 10, the Centers for Medicare & Medicaid Services (CMS) proposed to extend virtual direct supervision—i.e., the ability to provide direct supervision through real-time, audio-visual technology (rather than in-person...more

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2023

A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more

A&O Shearman

Generative AI and the EU AI Act – a closer look

A&O Shearman on

When the European Commission first released its proposal for an Artificial Intelligence Act in April 2021, generative AI was far from being an immediate concern of regulators. That of course all changed with the recent surge...more

Bradley Arant Boult Cummings LLP

CMS Proposes to Continue Allowing Remote Supervision Through December 31, 2024

In its Calendar Year (CY) 2024 Physician Fee Schedule (PFS) proposed rule, the Centers for Medicare and Medicaid Services (CMS) proposes to continue to allow supervising physicians and practitioners to conduct “direct...more

Perkins Coie

NLRB Prepares To Issue New Joint Employer Standard in 2023

Perkins Coie on

The National Labor Relations Board (the Board) released its notice of proposed rulemaking (Proposed Rule) to establish a new “joint employer” legal standard under the National Labor Relations Act (NLRA) on September 6, 2022....more

ArentFox Schiff

NLRB’s Proposed New Rule Would Expand Joint Employer Status to Entities With Indirect Control Over Worker Conditions

ArentFox Schiff on

Does anyone feel like they’ve seen this movie before? On September 6, the National Labor Relations Board (NLRB or “the Board”) announced a notice of proposed rulemaking that dramatically changed the joint employer analysis...more

Baker Donelson

Agency's About-Face: CMS Proposes Changes to Supervision Rules for Hospital Outpatient Therapeutic Services

Baker Donelson on

Among the many provisions in the FY 2020 Outpatient Prospective Payment System (OPPS) proposed rule is one that would alter the supervision standards applicable to hospital outpatient therapeutic services. See 84 Fed. Reg....more

A&O Shearman

US Federal Reserve Vice Chairman Randal Quarles Discusses Streamlining the Supervision and Regulation of Large Financial...

A&O Shearman on

U.S. Board of Governors of the Federal Reserve System Vice Chairman for Supervision, Randal Quarles, discussed the tailoring of supervision and regulation for large financial institutions. Vice Chairman Quarles noted that...more

Dorsey & Whitney LLP

Medicare Proposes Continued Relief for Critical Access and Rural Hospitals Through 2-Year Moratorium on Direct Supervision...

Dorsey & Whitney LLP on

On July 13, 2017, CMS released a proposed rule as part of its 2018 Outpatient Prospective Payment System proposals that is aimed at helping to reduce some of the burdens rural hospitals experience in recruiting physicians....more

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