We promise we didn’t just spill a can of alphabet soup in the title of this post! If your company’s website hosts user-generated content, or UGC (more acronyms!), you may be able to take advantage of a provision under US...more
On June 3, the CFPB issued its final rule codifying its “repeat offender registry.” The registry will require certain nonbank entities subject to agency or court orders issued in connection with the provision of a consumer...more
The CFPB has issued a final rule to provide transparency and track certain covered nonbank offenders. On June 3, 2024, the CFPB introduced a significant regulatory measure known as the Registry of Nonbank Covered Persons...more
The Occupational Safety and Health Administration (OSHA) defines a "willful" violation as one where the employer either knowingly failed to comply with a legal requirement or acted with plain indifference to employee safety....more
In her 2023 Enforcement Report, Solicitor of Labor Seema Nanda revealed enhanced coordination with OSHA to hold employers and supervisors accountable for repeat and willful violations, especially those that lead to worker...more
In September 2022, the federal Occupational Safety and Health Administration issued a directive expanding the scope of its Severe Violator Enforcement Program (SVEP). SVEP singles out employers that OSHA concludes have...more
The complaint, filed in the U.S. District Court for the Southern District of Florida, alleges that a non-bank residential mortgage loan originator violated the Home Mortgage Disclosure Act ("HMDA") by submitting inaccurate...more
In the weeks surrounding Labor Day 2023, the National Labor Relations Board overturned precedent with decisions and rules significantly impacting both union and non-union employers. The result is labor laws encouraging both...more
On May 24, 2023, Governor Tina Kotek signed into law legislation raising the maximum penalties for workplace fatality–related citations in Oregon far above federal limits. The law took effect immediately....more
On April 20, 2023, the National Labor Relations Board ("NLRB" or the "Board") issued a decision in Noah's Ark Processors, LLC d/b/a WR Reserve, 372 NLRB No. 80 (2023) in which it announced a non-exhaustive list of remedies...more
The National Labor Relations Board (NLRB or Board) decision in Noah's Ark Processors, LLC and United Food and Commercial Workers Local Union No. 293 went beyond ruling on the issues and provided a detailed list of the...more
If the NLRB finds that you have committed an unfair labor practice (and maybe more than once), just what can it do? In Noah’s Ark Processors, a three-member panel of the board recently took an opportunity to pronounce...more
On April 4, CFPB Director Rohit Chopra delivered remarks at the International Association of Privacy Professionals’ Global Policy Summit on the importance of reigning in repeat violators of consumer finance and privacy laws....more
Those of us who deal with the Occupational Safety and Health Administration (OSHA) have watched with interest the agency’s ongoing enforcement efforts against the Dollar General retail chain. Since 2017, OSHA has assessed...more
In recent years, we have written extensively about the huge increases in fines and other penalties assessed by the federal Occupational Safety and Health Administration (OSHA). These fines are multiplied in situations where...more
The Occupational Safety and Health Administration (OSHA) has increased its minimum and maximum penalties for workplace safety and health violations by 7.7 percent effective January 17, 2023. Today, a “serious” violation...more
On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General Lisa Monaco delivered remarks on Corporate Criminal Enforcement at the NYU Program on Corporate Compliance and Enforcement and announced new guidance...more
On September 15, 2022, the Occupational Safety and Health Administration (OSHA) published Directive Number CPL 02-00-169, a new instruction to its enforcement arm, updating policies and procedures for OSHA’s Severe...more
On April 21, the CFPB and New York Attorney General’s Office filed a complaint against a remittance provider alleging that the provider (i) repeatedly gave senders inaccurate information about when their remittance transfers...more
The Consumer Financial Protection Bureau (CFPB) has made it clear that corporate recidivism is now a top priority of its enforcement efforts. On March 28, 2022, CFPB Director Rohit Chopra delivered a lecture, titled Reining...more
On Tuesday, October 27, 2020, the U.S. Court of Appeals for the Tenth Circuit issued a long- awaited decision in Sec’y of Labor v. Wynnewood Refining Co., LLC. That case originated in 2012 when OSHA inspected the company...more
The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has now issued its second set of coronavirus-related citations, this time against an Ohio health-care company. OSHA inspected three of the...more
On 21 November 2019 a bill imposing multi-million Ruble (RUB) fines for infringing Russian data localization and information security laws passed the last hearing at the State Duma. This likely means that the bill will become...more
Congress took employers by surprise when it increased Occupational Safety and Health Administration (“OSHA”) penalties nearly 80 percent in 2016. Today, a Serious violation can fetch a maximum penalty of $13,260, and a...more
Seyfarth Synopsis: New Review Commission decision refines the definition of what OSHA must prove to establish a “Repeat” violation....more