After a long and tortured route through the courts, the SEC’s final rule implementing Dodd-Frank’s Resource Extraction Payment Disclosure requirement took effect today.
Many have watched and commented on the new Rule 13q-1, and for good reason. It is likely to have a significant impact — at least in the short term — on
The Consumer Financial Protection Bureau (“CFPB”) recently issued 293 pages of proposed changes (the “Amendments”) to the federal mortgage disclosure requirements it propounded in October 2015 commonly known as the TILA/RESPA Integrated Disclosure (“TRID”) or “Know Before You Owe” rule. The changes are many, but the rulemaking is not intended to review policy decisions behind
France will soon change the anti-corruption landscape with a new law aimed at reducing foreign bribery. Finance Minister Michel Sapin introduced the new law in July 2015 with hopes of aligning France’s efforts with those of the U.S., UK, and other countries. The draft law was formally introduced in March 2016, but it has since
On July 14, 2016, the Securities and Exchange Commission announced the settlement of an enforcement action against RiverFront Investment Group (“RiverFront”), an investment advisory firm, for failing to properly prepare clients for transaction costs.
At issue is a wrap fee program, in which a subadviser uses a sponsoring brokerage firm to execute their trades on
On F
riday, July 8, 2016, the Securities and Exchange Commission (SEC) announced Sean McKessey, Chief of the SEC’s Office of the Whistleblower, will be leaving his post by the end of the month. Jane Norberg, Deputy Chief of the SEC’s Office of the Whistleblower will serve as Acting Chief until a replacement is found.
Las
t Thursday, July 7, 2016, a divided panel of the U.S. Court of Appeals for the 8th Circuit upheld a three-month jail sentence against Austin “Jack” DeCoster and his son Peter, the CEO and COO respectively of Quality Egg LLC. The CDC determined that Quality Egg was responsible for a salmonella outbreak that ultimately
The Department of Justice has raised the bar on penalties for violations of federal immigration law. On June 30, 2016, DOJ issued an interim final rule that goes into effect on August 1, 2016. This rule, implemented as an inflation adjustment, increases the fines for employing unauthorized workers, for Form I-9 paperwork violations, and for
In April 2016, the Department of Justice (DOJ) announced its Foreign Corrupt Practices Act Enforcement Plan and Guidance, which includes a one-year pilot program to incentivize individuals and companies to voluntarily self-disclose Foreign Corrupt Practices Act-related (FCPA) misconduct, cooperate with DOJ investigations and remediate controls and compliance programs. Under the guidance, the DOJ may
Recently, the 
Supreme Court handed down its much-anticipated opinion in Universal Health Services, Inc. v. United States ex rel. Escobar et al.—a case addressing the viability of the implied certification theory in FCA litigation. Justice Thomas, writing on behalf of a unanimous Court, found that the implied certification theory can in fact serve as
The Consumer Financial Protection Bureau (CFPB) recently released a 23-page report claiming that single-payment vehicle title loans result in vehicle repossessions for nearly one in five borrowers. While this report has been questioned, it also claims that the average annual percentage rate for such loans is approximately 300 percent. These findings are based