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Interagency Guidance

Baker Botts L.L.P.

OMB Issues New Guidance on Acquisition of AI in the Federal Government

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The Office of Management and Budget (OMB) has released Memorandum M-24-18, introducing new requirements and guidance for federal agencies on the responsible acquisition of artificial intelligence (AI). This memorandum aims to...more

Baker Botts L.L.P.

Developing IP Issues in Energy Technology and Renewables

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In 2023, global investments in energy transition projects surged to approximately $1.7 trillion. This unprecedented investment level underscores the transformative shift toward cleaner energy sources and technologies....more

Morrison & Foerster LLP

MoFo’s State + Local Government Enforcement Newsletter - August 2024

Morrison Foerster’s State and Local Government Task Force is pleased to provide our bimonthly newsletter summarizing some of the most important and interesting developments from state attorneys general across the country and...more

Troutman Pepper

Regulators Promote “All-of-Government” Solar Energy Market Initiative

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On August 7, the U.S. Department of Treasury hosted a virtual briefing to discuss the steps that the Biden-Harris administration is taking to address perceived unfair and deceptive practices in the consumer solar energy...more

Mayer Brown

US Regulators Propose Data Standards to Implement the Financial Data Transparency Act

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Several federal financial regulators (the “Agencies”) have approved and published an interagency proposal to establish data standards that promote interoperability of financial regulatory data across these agencies (the...more

Jackson Lewis P.C.

Where Does the End of Chevron Deference Leave ERISA?

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For the last 40 years, judges were required to defer to administrative agencies’ reasonable interpretations of ambiguous federal statutes under Chevron v. Natural Resources Defense Council. The Supreme Court upended that...more

Vinson & Elkins LLP

DOE Issues Final Rule on Coordination of Federal Authorizations for Electric Transmission Facilities

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The United States electric grid is becoming increasingly stressed as the nation navigates the energy transition and demand for electricity rises. On May 1, 2024, recognizing the stress on the grid and the need for additional...more

Troutman Pepper

FOIA Exemption Questions on Redacted HHS Cannabis Letter

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The principle of open government is foundational to a healthy democracy, and the availability of government records upon request from the public is one of its chief cornerstones. Originally published in Law360 - January 5,...more

Venable LLP

Tinker, Tailor, Banker, FSOC Designation: New Guidance for Bank-like Regulation and Supervision of Non-Banks

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Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more

Snell & Wilmer

Climate-Related Financial Risk Management Final Interagency Guidance Rules Issued – Now What’s Next?

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On October 24, 2023, the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) issued the joint agency climate-related financial risk management guidance for...more

Venable LLP

Stressed Out - Final Interagency Guidance on Climate Risk Management for Large Banks

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The federal banking agencies recently issued final interagency guidance concerning how large banks may control for climate-related financial risks (“climate risks”). The guidance is largely consistent with the proposal and...more

Cozen O'Connor

FTC, DOL Partner to Protect Workers

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The FTC and the U.S. Department of Labor (DOL) signed an agreement to increase inter-agency cooperation in combatting anticompetitive behavior and unfair and deceptive acts and practices that harm workers....more

Troutman Pepper

Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast

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In this episode of The Consumer Finance Podcast, Troutman Pepper Partner Chris Willis and fellow Partner Glen Trudel discuss the Final Interagency Guidance put out by the Federal Reserve, the FDIC, and the OCC regarding...more

Davis Wright Tremaine LLP

Deadline Extended: ONCD Seeking Public Feedback on Ways to Harmonize Cybersecurity Regulations

The Office of the National Cyber Director (ONCD) has extended the deadline to respond to its Request for Information (RFI) seeking public comment on "opportunities for and obstacles to harmonizing" cybersecurity regulations....more

Davis Wright Tremaine LLP

The Regulatory Trio: Long-Term Debt and Resolution Plan Proposals Signal Need for Greater Clarity and Simplification

On August 29, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (collectively, FBAs) issued requests for...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

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On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Bradley Arant Boult Cummings LLP

CFPB, FDIC, NCUA, OCC, and FRB Issue Proposed Guidance on Reconsiderations of Value of Residential Real Estate Transactions

Consistent with concerns surrounding bias in property valuations, on June 8, 2023, the Consumer Financial Protection Bureau (CFPB), the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal...more

Cozen O'Connor

Final Interagency Guidance on Managing Risks Associated with Third-Party Relationships

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On June 6, 2023, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp. (collectively, the “Agencies”) issued final interagency guidance that...more

Latham & Watkins LLP

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

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The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Cadwalader, Wickersham & Taft LLP

Agencies Issue Proposed Interagency Guidance on Real Estate Appraisal Reconsiderations of Value

Last week, the Office of the Comptroller of the Currency (“OCC”), Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), and the Consumer Financial...more

Ballard Spahr LLP

Federal banking agencies issue final interagency guidance on risk management in third-party relationships

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The Federal Reserve, FDIC, and OCC have released final interagency guidance for their respective supervised banking organizations on managing risks associated with third-party relationships, including relationships with...more

Perkins Coie

New York State Initiates Interagency Enforcement Actions Against Unlicensed Cannabis Businesses

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On June 8, 2023, Gov. Kathy Hochul (D) announced a crackdown on sales by unlicensed cannabis sellers, which could face fines of up to $20,000 a day under recent legislation allowing for enhanced enforcement. The legislation...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Extend Reg. O Relief

On December 22, just before many of us may have started turning to our holiday breaks, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)...more

Orrick, Herrington & Sutcliffe LLP

Agencies warn banks of crypto-asset risks

On January 3, the FDIC, Federal Reserve Board, and OCC issued a joint interagency statement highlighting key risks banks should consider when choosing to engage in cryptocurrency-related services. ...more

Wiley Rein LLP

Office of the National Cyber Director Remains Nascent, Evaluations to Come as Efforts Mature

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In 2021, Congress created a new cyber leadership position within the White House, enacting a suggestion from the Cyberspace Solarium Commission, to develop a new Office of the National Cyber Director (ONCD). ...more

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