News & Analysis as of

Third-Party New Guidance

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

Venable LLP on

It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

Sterne, Kessler, Goldstein & Fox P.L.L.C.

MarkIt to Market® - August 2023

Thank you for reading the August 2023 issue of Sterne Kessler's MarkIt to Market® newsletter. This month, we conclude our series that explores ways to lose trademark rights with an examination of naked licensing, discuss a...more

Sheppard Mullin Richter & Hampton LLP

FTC Publishes INFORM Act Guidance for Third Party Sellers

On August 18, the FTC published guidance for third party sellers detailing how the INFORM Consumers Act, which took effect on June 27, may impact their businesses. The INFORM Act provides that online marketplaces where...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Jenner & Block

Client Alert: Bank-Fintech Partnerships Update: Banking Agencies Finalize Key Risk Management Guidance

Jenner & Block on

On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more

Buchalter

FDIC, FRB & OCC Issue Interagency Guidance on Third-Party Relationships: Risk Management

Buchalter on

June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more

Perkins Coie

DOJ Issues New Guidance on Use of Personal Devices and Third-Party Messaging Applications

Perkins Coie on

The U.S. Department of Justice (DOJ) announced significant new guidance on March 3, 2023, regarding the use of personal devices and the retention of corporate communications. The DOJ’s concern regarding the use of personal...more

Holland & Knight LLP

U.S. Department of Education Issues New Guidance on Third-Party Servicers

Holland & Knight LLP on

The U.S. Department of Education (Department) published its newest "Dear Colleague Letter" (DCL ID: GEN-23-03) on Feb. 15, 2023, making sweeping changes to the regulation of agreements between institutions of higher education...more

Perkins Coie

New DOJ Guidance on Personal Devices and Third-Party Messaging Applications Applies to Any Company DOJ May Scrutinize

Perkins Coie on

The U.S. Department of Justice (DOJ) recently released new guidance announcing several policy changes to further strengthen and clarify its approach to prosecuting corporate crime. The guidance, released through a memorandum...more

Pullman & Comley - Labor, Employment and...

Mortgage or other Third Party Loan Investments in Your Plan?  Do they Pass Muster under IRS Issue Snapshot?

The IRS Issue Snapshot-Third Party Loans from Plans dated August 23, 2022 is a short advice document for examiners to use when auditing tax-qualified retirement plans that invest in mortgages or other third party loans. IRS...more

Dorsey & Whitney LLP

President Biden Signs New Law Requiring U.S. Blockage of All Imports Made Wholly or Partly in Xinjiang, China

Dorsey & Whitney LLP on

President Biden signed into law on December 23 legislation that will, for the first time, require U.S. Customs and Border Protection (“CBP”) to detain all imports that are made wholly or partly in the Xinjiang Uyghur...more

Mitratech Holdings, Inc

US Regulators Raise Expectations of Third-Party Risk Management

Mitratech Holdings, Inc on

It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...more

Jackson Lewis P.C.

Cal OSHA Offers Additional Guidance For Its COVID-19 Emergency Temporary Standards: Testing Sites And Scope Of Coverage

Jackson Lewis P.C. on

It has been three months since California approved the Division of Occupational Safety and Health’s (“Cal OSHA”) COVID-19 Emergency Temporary Standard (“ETS”). The rushed implementation of Cal OSHA’s ETS, which imposed new...more

Jackson Lewis P.C.

COVID-19 Deadline Extensions—No More Time Outs But No Single Deadline Either!!

Jackson Lewis P.C. on

We recently provided an update on the looming end date for COBRA and other deadline extensions and the uncertainty that continues to add to the administrative burdens without more clarity from the DOL and IRS. Message...more

Bradley Arant Boult Cummings LLP

CCPA and AdTech: Mark Your Calendar for July 31st

A little more than six months ago, we addressed the challenges businesses faced in complying with CCPA when it came to their use of third-party adtech such as pixels, beacons and trackers. In line with the evolving nature of...more

Chambliss, Bahner & Stophel, P.C.

OCR Provides Guidance on Providers Contacting Former COVID-19 Patients About Blood and Plasma Donation

The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services recently released guidance clarifying that, in certain circumstances, providers may, in a HIPAA-compliant manner without obtaining...more

Troutman Pepper

OCC Bulletin For Third-Party Oversight Breaks New Ground For Bank Relationships With Fintechs

Troutman Pepper on

New third-party oversight guidance issued by the OCC should spur increased financial innovation at national banks. On March 5, the OCC issued OCC Bulletin 2020-10, Frequently Asked Questions to Supplement OCC Bulletin...more

Bricker Graydon LLP

FTC announces new and improved data security guidance

Bricker Graydon LLP on

On January 6, 2020, Andrew Smith, Director of the Federal Trade Commission (FTC) Bureau of Consumer Protection, announced three significant improvements to the FTC’s approach to data security enforcement cases....more

Dechert LLP

Cookies, Consent and Compliance: ICO Publishes New Guidance

Dechert LLP on

Cookies are files of information which a provider of an online service, such as a website operator, can store on a user’s device. On subsequent visits, the website can access information stored in the cookies to tailor the...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and...

The Volkov Law Group on

The Justice Department’s new Corporate Compliance Guidance is keyed to the concept of a “well-designed compliance program.” Under this concept, we first examined risk assessments and policies and procedures. ...more

Carlton Fields

Three Takeaways From The DOL's New Labor Condition Application Form

Carlton Fields on

Effective Nov. 19, U.S. employers seeking to file H-1B, H-1B1 and E-3 petitions (extension, new or amendment) must use the new ETA 9035 form, the legally required Labor Condition Application (LCA). The most important changes...more

Williams Mullen

DOJ/EPA Memos Change Enforcement Policies

Williams Mullen on

Three memoranda, two issued by the United States Department of Justice (“DOJ”) and one issued by EPA, mark a significant shift in how the federal government approaches civil and criminal enforcement for violations of...more

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