On December 5, 2016 the PCAOB announced that it had settled charges against Brazil-based Deloitte Touche Tohmatsu Auditores Independentes for a record $8 million civil penalty. PCAOB News...
To be guilty of insider trading, a tipper of inside information must receive a “personal benefit” in exchange for his tips. On December 6, 2016, the Supreme Court unanimously held in ...
In October 2016, the U.S. federal banking agencies jointly issued an advance notice of proposed rulemaking regarding enhanced cyber risk management standards (the “Enhanced Standards”...
Not surprisingly, the many media and political reactions to the PHH Corp. v. CFPB decision have reflected the competing stakeholder interests around every aspect of the CFPB.In this memor...
In September 2016, the New York State Department of Financial Services (the “NYDFS”) proposed new cybersecurity regulations (the “Proposed Rules”) for banks, insurance companies a...
On June 1, 2016, the United States Court of Appeals for the Second Circuit held that federal courts do not have jurisdiction to hear constitutional challenges to ongoing Securities and Ex...
On May 23, 2016, the United States Court of Appeals for the Second Circuit reversed a $1.3 billion civil penalty imposed against Countrywide Home Loans, Inc., Bank of America, N.A., and r...
On April 5, 2016, the U.S. Department of Justice (“DOJ”) launched a new one-year pilot program encouraging voluntary self-disclosure of misconduct related to the Foreign Corrupt Pract...
A recent Court of Appeals decision sharply limits the authority of judges to reject Deferred Prosecution Agreements (“DPAs”). On April 5, 2016, the U.S. Court of Appeals for the Distr...
On March 2, 2016, the CFPB announced that it had settled an enforcement action with Dwolla, Inc., an online payment platform, for making allegedly deceptive statements regarding its data ...
