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The new identity theft red flags rules - get ready!

Day Pitney LLP
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USA
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May 10 2013

In our April 15 Alert, we discussed the Securities and Exchange Commission's and the Commodity Futures Trading Commission's new rules requiring

SEC and CFTC mandate strict identity theft prevention compliance

Day Pitney LLP
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USA
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April 15 2013

On April 10, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) (together, the Commissions) jointly

Connecticut's Insurance Department issues tough notice requirement for data breaches

Day Pitney LLP
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USA
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September 13 2010

Following on the heels of Health Net's recent settlement with the Connecticut Attorney General for alleged failure to secure medical records and financial information and promptly notifying consumers and regulators of the breach, the Insurance Department issued a bulletin on August 18, 2010 mandating immediate notification to the Department of data breaches by licensees and registrants of the Department

Proposal to update COSO's internal control framework

Day Pitney LLP
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USA
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January 3 2012

The Committee of Sponsoring Organizations of the Treadway Commission (COSO) has recently issued a proposed update to its internal control framework

CMS considers mandating fraud reporting by Medicare advantage plans

Day Pitney LLP
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USA
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March 7 2012

The Centers for Medicare & Medicaid Services (CMS) is ratcheting up its efforts to have Medicare Advantage (MA) organizations take more aggressive actions to combat fraud and abuse

FERC issues order proposing nearly a half-billion dollars in civil penalties

Day Pitney LLP
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USA
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November 5 2012

On Halloween the Federal Energy Regulatory Commission (FERC) issued an order1 (Order) directing Barclays Bank PLC (Barclays) and four individuals from its Western U.S. electricity trading operations (Traders) to show cause why they should not be found to have violated the Federal Power Act and FERC prohibitions against energy market manipulation

FTC amends identity theft rule to narrow definition of covered entities

Day Pitney LLP
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USA
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December 10 2012

After a three-year delay amid a swirl of controversy and litigation over the types of entities covered under the Identity Theft Red Flags Rule ("Red Flags Rule"), the Federal Trade Commission ("FTC") has bowed to the will of Congress and amended the rule to limit the scope of covered entities, as reported in the Federal Register on December 6 77 FR 72712

NY State Comptroller bans pension fund "pay-to-play" political contributions

Day Pitney LLP
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USA
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September 25 2009

New York State Comptroller Thomas P. DiNapoli issued an executive order on September 23, 2009 prohibiting the $116.5 billion New York State Common Retirement Fund ("Fund") from doing business with any investment adviser who has made a political contribution to the State Comptroller or a candidate for State Comptroller

Delaware court affirms directors' business judgment in handling the current financial crisis

Day Pitney LLP
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USA
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March 4 2009

In the recent Citigroup decision, the first to assess director responsibilities in the current financial crisis, the Delaware Chancery Court affirmed Citigroup's board of directors' business judgment in managing the risks involving Citigroup's financial exposure to the subprime mortgage market

FTC delays Identity Theft Red Flags Rule for fourth time

Day Pitney LLP
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USA
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November 2 2009

On October 30, 2009, just two days before the November 1 enforcement date, the Federal Trade Commission ("FTC") delayed yet again enforcement of the Identity Theft Red Flags Rule until June 1, 2010

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