News & Analysis as of

Third-Party Service Provider Comment Period

Littler

OSHA Wants to Revise its Worker Walkaround Representative Policy – Should Employers Be Concerned?

Littler on

On August 29, 2023, the U.S. Occupational Safety and Health Administration (OSHA) released a proposed rule that would resurrect an Obama-era policy that allowed employees to designate third-party representatives to accompany...more

Eversheds Sutherland (US) LLP

NAIC releases highly-anticipated draft model bulletin on artificial intelligence systems used by insurers

On July 17, 2023, the Innovation, Cybersecurity and Technology (H) Committee of the National Association of Insurance Commissioners (NAIC) released for comment a highly anticipated model bulletin (Model Bulletin) on...more

WilmerHale

SEC Proposes to Expand Reg SCI

WilmerHale on

The Securities and Exchange Commission (SEC) proposes to amend Regulation Systems Compliance and Integrity (Reg SCI) to update and expand the regulatory oversight of the core technology of the U.S. securities markets.1 The...more

Cooley LLP

ED Updates Timeline for Third Party Servicer Guidance

Cooley LLP on

The Department of Education has extended the timeline for implementation of its February 15 Dear Colleague Letter, which substantially expanded the “third-party servicer” definition under the Title IV regulations....more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes Rule on Outsourcing by Investment Advisers

On October 26, 2022, the U.S. Securities and Exchange Commission (SEC) proposed a new Rule 206(4)-11 and amendments to Rule 204-2 under the U.S. Investment Advisers Act of 1940 (Advisers Act), as well as amendments to Form...more

Quarles & Brady LLP

The Clock is Ticking: Comments to Proposed Federal Rules For Wholesalers and 3PLs are Due June 6th and Here’s What We Think

Quarles & Brady LLP on

On February 4, 2022, the FDA released its long-awaited proposed national standards for the licensure of third party logistics providers (3PLs) and wholesale drug distributors. The draft rules were years over-due and the delay...more

Stinson LLP

Medical Device Third-Party Servicers: Will FDA Treat You as a Manufacturer?

Stinson LLP on

Recently, in response to requests by stakeholders, FDA extended the deadline for comments to its draft guidance "Remanufacturing of Medical Devices," which provides the agency's current thinking regarding the distinction...more

Sheppard Mullin Richter & Hampton LLP

Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships

On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more

Eversheds Sutherland (US) LLP

Twisting in the Wind - California Attorney General issues revised CCPA regulations

On February 10, 2020, the California Attorney General published revisions to the proposed regulations (Revised Regulations) to implement the California Consumer Privacy Act of 2018 (CCPA). The changes largely clarify and...more

WilmerHale

California Attorney General Publishes Long-Awaited Proposed Regulations Implementing the CCPA

WilmerHale on

On October 10, 2019, California Attorney General Xavier Becerra proposed regulations and issued an explanatory statement, “Initial Statement of Reasons,” aimed at clarifying the scope of the California Consumer Privacy Act...more

Katten Muchin Rosenman LLP

CMS Issues Draft Guidance for Hospital Co-Location

On May 3, CMS issued a draft letter to State Survey Agency Directors regarding "Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities" ("Guidance") that is intended to provide clarity on how...more

Carlton Fields

NY DFS Proposed Cybersecurity Regulations Revised and Implementation Delayed

Carlton Fields on

We previously reported on the New York Department of Financial Services’ proposed cybersecurity regulations. During the public comment period, the DFS received over 150 comments. In response, the DFS announced on December 28,...more

Ballard Spahr LLP

NYDFS Revises Cybersecurity Regulation, Extends Effective Date to March 1, 2017

Ballard Spahr LLP on

The New York Department of Financial Services (NYDFS) announced today a revised regulation that will require all institutions subject to NYDFS supervision to establish and maintain a cybersecurity program meeting "certain...more

Stinson - Corporate & Securities Law Blog

The New York State Department of Financial Services Proposes Robust Cybersecurity Rules

On September 13, 2016, the New York State Department of Financial Services (DFS) proposed new rules that would require certain “Covered Entities” to establish and implement cybersecurity programs designed to protect nonpublic...more

Robinson+Cole Data Privacy + Security Insider

NAIC Released Revised Insurance Data Security Model Law Draft For Review

The National Association of Insurance Commissioners (NAIC) Cybersecurity Task Force released a revised draft of the Insurance Data Security Model Law (Model Law) last week. The Model Law’s goal is to “establish exclusive...more

Proskauer Rose LLP

SEC Proposes Rule Requiring Registered Advisers to Adopt Business Continuity and Transition Plans

Proskauer Rose LLP on

On June 28, 2016, the Securities and Exchange Commission (SEC) proposed new Rule 206(4)-4 under the Investment Advisers Act of 1940 (Advisers Act) that would require registered investment advisers to adopt and implement...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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