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Advisory Opinions Third-Party Service Provider

Venable LLP

OIG Reminds Us that Flat Fee Business Arrangements Aren’t Immune from AKS Scrutiny

Venable LLP on

On July 1, 2025, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 25-08, concluding that a medical device manufacturer’s proposed payment to access a...more

BCLP

CFPB guidance on pay-to-pay fees impacts consumer loan agreements

BCLP on

Consumer debt collectors may not be permitted to charge consumers “convenience fees” for card payments, which the Consumer Financial Protection Board (the “CFPB”) calls “pay-to-pay” fees, unless the underlying loan agreement...more

Proskauer - Minding Your Business

A Cloud on the Horizon? Attorneys’ Obligations when Using a Third-Party’s Cloud-Based Services

When we think of clouds, we likely picture cumulus, stratus, and cirrus ones, not the type of “cloud” that holds data and software. The latter type of cloud is generally controlled by a third-party service provider and is...more

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