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  • Blog
    August 28, 2020
    Proposed Rule for Drug Enforcement Administration Theft Reporting
    On Wednesday, July 29, 2020, the U.S. Department of Justice’s Drug Enforcement Administration (DEA) proposed a new rule that clarifies that the submission of DEA Form 106 (Report of Theft or Loss of Controlled Substances) shall be submitted electronically through the DEA Diversion Control Division’s secure network within fifteen (15) days of discovery and must be “complete and accurate.” The…
  • Blog
    August 31, 2020
    As Regulators Boost Market Surveillance Capabilities, Firms Should Enhance Self-Monitoring to Reduce Trading Violations
    Regulatory fines in any industry are not new. For as long as there have been regulations, hefty fines have served as the clearest and most concise method for regulators to publicly rebuke corporate offenders and wrongdoers. Over the last decade, the financial services industry has seen multiple billion-dollar fines, and they have been so recurrent that the public and media are almost…
  • Blog
    September 9, 2020
    The Critical Importance of Employee Wellbeing in the Time of COVID-19
    In the best times, leaders know that people – or human capital – are the heart of a successful organization. In challenging times, this concept is even more magnified; it’s the key to survival. The global Coronavirus pandemic (COVID-19) is delivering unprecedented challenges to businesses all over the globe. As organizations seek to adapt, COVID-19 has created a “new normal” for employees –…
  • Blog
    December 16, 2020
    CFPB Provides Further Guidance on MSAs Under RESPA Section 8
    The Consumer Financial Protection Bureau (CFPB) issued a compliance aid in October 2020 to provide regulated entities greater clarity around the Real Estate Settlement Procedures Act (RESPA) and certain provisions of Regulation X. The compliance aid, presented in the form of Frequently Asked Questions (FAQs), focuses on RESPA Section 8, which prohibits certain actions related to federally related…
  • Blog
    December 18, 2020
    FinCEN and OFAC Put Financial Institutions on Notice About Processing Ransomware Payments
    The U.S. government has officially put financial institutions on notice: It is watching and may impose anti-money laundering (AML) sanctions on payment facilitators if they violate federal laws on engaging in transactions, such as ransomware payments, with sanctioned individuals or entities – intentionally or otherwise. For as long as ransomware incidents have occurred, the controversial issue…
  • Blog
    December 18, 2020
    SolarWinds Vulnerability Update – Indicators of Compromise and Recommended Actions
    The news of the cyber attacks being experienced by government agencies and an expanding list of organizations continues to grow and change on almost an hourly basis. This is proving to be potentially one of the most significant cyber breaches in recent times. Following up on our December 14, 2020, Flash Report on the CISA advisory, and in response to numerous questions and inquiries we continue…
  • Blog
    December 21, 2020
    A Farewell to Paul Sarbanes
    Almost four years ago, I wrote a blog, “A Farewell to Michael Oxley,” paying tribute to the former Republican member of the U.S. House of Representatives who died on January 1, 2016. Today, it is fitting that we issue another farewell. On December 7, the family of Paul Sarbanes announced the death of the former Democratic senator the previous day. Together, these two men co-authored the landmark…
  • Blog
    December 30, 2020
    PPP 2.0 – A Renewed Opportunity (and New Set of Headaches) for Lenders
    As the old saying goes, the best deals are made when neither side gets exactly what it wants. By that standard, the most recent federal pandemic relief bill that finally passed into law in late December certainly qualifies as a great deal. Democrats who for months had been seeking a bill in excess of $3 trillion were certainly disappointed by the final price tag of slightly more than $900…
  • Blog
    January 8, 2021
    SPACs Are Hot But Be Well Prepared – The SEC Is Watching
    The prevalence of Special Purpose Acquisition Companies (SPACs) has expanded dramatically over the past year as organizations capitalize on a more streamlined path to public ownership. But key steps still must be taken and regulatory requirements still must be observed to protect shareholders. The U.S. Securities and Exchange Commission (SEC) is watching, and SPAC sponsors need to be ready for…
  • Blog
    January 12, 2021
    Pandemic-Driven Issues Complicating Tech CFOs’ 2021 Spending Decisions
    Even for high-growth technology companies that performed fairly well during the last 12 months, 2021 capital-spending decisions are being made with significant restraint and apprehension. The ongoing rollout of promising COVID-19 vaccines notwithstanding, the pandemic’s far-reaching effects on consumer behavior, the labor market, wages, office space, technology and supply chains, to name a few,…
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