News & Analysis as of

Policies and Procedures Civil Monetary Penalty Enforcement Actions

Saul Ewing LLP

OCR Imposes $200,000 Civil Money Penalty Against HIPAA-Covered Entity

Saul Ewing LLP on

On March 6, 2025, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced a civil money penalty (“CMP”) of $200,000 against Oregon Health & Science University (“OHSU”) for failing to...more

Dorsey & Whitney LLP

SEC Settles with Five Investment Advisers for Marketing Rule Violations

Dorsey & Whitney LLP on

The SEC recently settled charges against five registered investment advisers for violations of the marketing rule (“Marketing Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”)....more

Holland & Knight LLP

SEC Settlements Over Whistleblower Protections Pile Up

Holland & Knight LLP on

As the SEC closed its fiscal year, it filed three separate enforcement actions against companies for purported violations of Rule 21F-17 under the Securities and Exchange Act of 1934, which prohibits persons from impeding...more

Seward & Kissel LLP

SEC Settles Charges with Nine Advisers in Marketing Rule Sweep

Seward & Kissel LLP on

Who may be interested: Investment Advisers. Quick Take: The SEC recently settled charges with nine investment advisers related to their use of hypothetical performance information on their websites without adopting or...more

Sheppard Mullin Richter & Hampton LLP

OCC Revises Policies and Procedures for Civil Money Penalties

On November 29, the OCC released a revised Policies and Procedures Manual relating to the assessment of civil money penalties (“CMP Matrix”), which will be effective as of January 1, 2023. The CMP Matrix is a reference guide...more

Jackson Lewis P.C.

“Get a Life” – Another Dentist Responds to Patient’s Online Review, This Time Faces a $50,000 OCR Penalty

Jackson Lewis P.C. on

It can be cathartic responding to a negative online review. It can also backfire, as can failing to cooperate with an OCR investigation as required under HIPAA. The Office for Civil Rights (OCR) recently announced four...more

King & Spalding

SEC Brings Action Against Morningstar Alleging Undisclosed CMBS Rating Adjustments

King & Spalding on

On February 16, 2021, the SEC filed a litigated civil complaint in the Southern District of New York against Morningstar Credit Ratings LLC, a former Nationally Recognized Statistical Rating Organization (“NRSRO”) alleging...more

UB Greensfelder LLP

The SEC Released A Risk Alert On Reg S-P, a/k/a How To Avoid A $1 Million Penalty

UB Greensfelder LLP on

I am hardly saying that SEC Regulation S-P is the sexiest of regulations. I mean, has any customer is history actually read one of those exciting statement stuffers that discloses in some dense font a BD’s privacy policy?...more

UB Greensfelder LLP

Wedbush Learns That It’s Not Enough Just To Spot Red Flags

UB Greensfelder LLP on

I have been busy the last month getting ready for a big arbitration, and attending the first week of what looks like is going to be a four- or five-week slog when all is said and done. So, I am just catching up on some recent...more

Proskauer - The Capital Commitment

SEC Settles with Private Equity Fund Adviser over Alleged Conflicts of Interest

As a sign that the SEC is continuing to actively pursue private equity fund advisers, on April 24, 2018, the SEC announced a settlement with private equity fund adviser WCAS Management Corporation (WCAS) related to...more

Sheppard Mullin Richter & Hampton LLP

Most Recent CFPB Supervisory Highlights Feature FCRA, LO Compensation and Debt Collection Issues

The Consumer Financial Protection Bureau’s most recent supervisory highlights publication featured issues relating to the Fair Credit Reporting Act, loan originator compensation and in-person debt collection that should be on...more

MoFo Reenforcement

CFPB’s Message to Employment Background Screening Providers: A Rose by Any Other Middle Name is Probably the Wrong Person

MoFo Reenforcement on

On October 29, the CFPB took action against two of the country’s largest employment background screening report providers for violations of the FCRA. This is one of the CFPB’s most significant FCRA actions to date, following...more

Proskauer on Privacy

SEC Cybersecurity Update

Proskauer on Privacy on

Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

King & Spalding

Investment Adviser Settles SEC Cybersecurity Enforcement Action; SEC Issues Investor Alert

King & Spalding on

On September 22, the U.S. Securities and Exchange Commission (“SEC”) and R.T. Jones Capital Equities Management, Inc. (“R.T. Jones”), a St. Louis-based investment adviser, settled charges that R.T. Jones failed to adopt...more

Foley Hoag LLP - Security, Privacy and the...

The SEC Charges Investment Adviser with Violating Regulation S-P by Failing to Adopt Cybersecurity Policies and Procedures

In recent years, the SEC has been focused on cybersecurity. It has issued risk alerts, conducted examinations and provided guidance about what the agency sees as widespread weaknesses in many policies and procedures to...more

Proskauer on Privacy

SEC Announces Cybersecurity Enforcement Action

Proskauer on Privacy on

On September 22, 2015, the Securities and Exchange Commission (SEC) announced the settlement of an enforcement action against a St. Louis-based registered investment adviser (Adviser) brought under Rule 30(a) of Regulation...more

Mintz - Consumer Product Safety Viewpoints

CPSC Suspends Over 90% of $3.5 Million Civil Penalty Due to Company’s Inability to Pay; phil&teds USA to Pay $200,000

At the very beginning of this year, we wrote that we expected the CPSC to remain active in bringing enforcement actions against companies for violations of the Consumer Product Safety Act (CPSA). About one month later, CPSC...more

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