The CFPB recently released its Fall 2014 Supervisory Highlights report, which details recent findings from CFPB exams of providers of consumer financial products and services. One of most cited regulatory issues continues to be violations deemed unfair, abusive, or deceptive acts or practices (UDAAP). The report highlighted those found in […]
Publications
ACOs and Tax-Exempt Financing
On October 24, 2014, the IRS released Notice 2014-67 which provides guidance for tax-exempt entities participating in ACOs as related to outstanding tax-exempt bonds. Particularly, the Notice provides (i) guidance relative to such an entity’s participation in an ACO; and (ii) a new private use safe harbor for management and […]
New FAQs Released by DOL Take Sharper Aim at Premium Reimbursement Arrangements for Individual Health Insurance, Marketplace Dumping
The DOL released a new set of Frequently Asked Questions (“FAQs”) on November 6, 2014, which seek to clarify its prior guidance with respect to the treatment of certain premium reimbursement arrangements under the Affordable Care Act (the “ACA”) and which could have a significant impact on how certain employers […]
HRSA Withdraws 340B Program “Mega-Rule” in Favor of Informal Guidance
After a federal court ruled that the Health Resources and Services Administration (HRSA) did not have statutory authority to promulgate regulations on the 340B Drug-Pricing Program’s orphan drug exclusion, the agency has announced it will instead clarify key 340B policy issues through informal guidance. Prior to that ruling, HRSA planned […]
NLRB Gives Employees Right to Use Employers’ Email for Union Organizing and Anti-Employer Communications
In another effort to support unions, the National Labor Relations Board issued a significant and long-awaited decision yesterday that gives most employees the right to use their employers’ email systems to encourage employees to form and support a labor union. In Purple Communications, Inc., 361 NLRB 126 (December 11, 2014), […]