On August 7, President Trump signed an Executive Order (the “Order”) aimed at financial institutions and intended to prevent unlawful “debanking,” which the order defines as denying an individual access to financial services based on the individual’s constitutionally protected beliefs, affiliates, or political views. The Order requires that any decision […]
Publications
State Data Privacy Law Update – Two States Limit GLBA Exemptions
By paring back on the broad entity level GLBA exemption, Montana and Connecticut have joined California, Minnesota, and Oregon as states that do not include a broad entity level GLBA financial institution exemption within their respective consumer data privacy laws. Montana On May 8, Montana Governor Greg Gianforte signed Senate […]
Nebraska Supreme Court Rejects Effort to Undermine the Enforceability of Personal Guaranties
Henderson State Company v. Garrelts, 319 Neb. 485 (2025) On July 18, 2025, the Nebraska Supreme Court issued a decision enforcing the plain language of two personal guaranties of bank loans. The decision rejected the effort of the guarantors to impose obligations on the lending bank beyond those contained in […]
The Medicare Shared Savings Program in the Trump Era
Many providers have made substantial investments in ACOs for participation in the Medicare shared savings program. As the Trump Administration makes significant changes to many government programs, many have questioned how the Administration will view this program. That concern was stoked by an announcement in March that four smaller CMS […]
A Boomerang Effect: Recent Regulatory Changes Involving Reproductive Health Care
Recent legal and regulatory changes around reproductive health care are creating a boomerang effect for the health care industry. On June 18, 2025, the U.S. District Court for the Northern District of Texas issued an order vacating the majority of the HIPAA Privacy Rule to Support Reproductive Health Care Privacy […]

