Publications

The Office of the Comptroller of the Currency recently released its “Garnishment of Accounts Containing Federal Benefit Payments” booklet, which is new to the Comptroller’s Handbook and establishes procedures that financial institutions must follow when they receive a garnishment order against an account holder who receives certain types of federal […]

Note: This is the first article in a 2-part series on HIPAA and data security and encryption. The June edition of the Health Law Advisory will include an article by James E. O’Connor of the Technology and Intellectual Property Practice Group. Four recent settlement agreements between health care organizations and […]

Banks should evaluate their security protocols and mechanisms for protecting their ATMs and customer accounts that are linked to prepaid and debit cards against a new type of bank heist. This direction comes from a joint statement by the members of the Federal Financial Institutions Examination Council (“FFIEC”). The U.S. […]

Part 1: Understanding the Market Banks, credit unions, retailers, payday loan companies, and even the U.S. Postal service have shown interest and have made efforts to serve unbanked and underbanked households in the United States. It seems that most financial institutions want a piece of the pie; however, some companies […]

On May 23, 2014, a federal district court invalidated the 340B Program’s orphan drug exclusion after finding that the U.S. Department of Health and Human Services (HHS) acted beyond its statutory authority when it implemented the rule. The 340B Program requires manufacturers to give substantial discounts on outpatient prescription drugs […]