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On July 29, Equifax determined that it had been subject to an IT breach that included sensitive information. A crisis team was formed to determine the scope of the intrusion and begin a n...
On June 12, 2018, the New York Court of Appeals overruled longstanding Appellate Division precedent and held that fraud claims brought by the New York Attorney General (“NYAG”) under ...
Eighty percent of the companies targeted by the New York City Comptroller responded, according to a press release announcing the results of its Boardroom Accountability Project 2.0.
The C...
In a June 28, 2018 release (the “Proposing Release”) the Securities and Exchange Commission (the “SEC”) proposed new Rule 6c-11 (the “Proposed Rule”) and form amendments to st...
Rules and Regulations
SEC Modernizes the Delivery of Fund Reports and Seeks Public Feedback on Improving Fund Disclosure and Fees Related to Forwarding Fund Materials
SEC Proposes FAIR A...
On June 27, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Iranian Transactions and Sanctions Regulations (“ITSR”), 3...
The Supreme Court’s opinion in Lucia v. SEC, holding that SEC ALJs qualify as Officers of the United States under the Constitution and are therefore subject to the Appointments Clause o...
Arguments surrounding the constitutionality of the CFPB’s structure, never fully put to rest despite the D.C. Circuit’s en banc decision in PHH v. CFPB, are back in the headlines this...
Not enough attention has been paid to the FFIEC’s policy announcement on enforcement which is, we hope, the first step toward fundamental change. The Policy Statement on Interagency No...