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HTMLSafe Harbor Update: Germany Restricts Alternatives for U.S. Data Transfers
Viola Bensinger, Carsten Kociok; Greenberg Traurig Germany, LLP;
Legal Alert/Article
October 29, 2015, previously published on October 27, 2015
Three weeks after the CJEU invalidated the EU-U.S. Safe Harbor Program in its ground-ruling judgment, as reported in our previous Alert, German privacy officials issued their long-awaited position paper yesterday. The position paper explains their analysis of the judgment and its consequences for...

 

HTMLFERC Clarifies Prohibition on Buy/Sell Arrangements
Gus Howard, Gregory K. Lawrence, Howard L. Nelson; Greenberg Traurig, LLP;
Legal Alert/Article
October 28, 2015, previously published on October 26, 2015
At the request of Rice Energy Marketing LLC, the Federal Energy Regulatory Commission (FERC), on Oct. 15, 2015, issued a Declaratory Order that clarified the extent to which releases of capacity to asset managers are exempt from FERC’s prohibition on buy/sell transactions. As clarified, the...

 

HTMLU.S. Sanctions Scuttle Honduran Bank, Raise Compliance Stakes
Kara M. Bombach, Jared E. Dwyer, Carl A. Fornaris; Greenberg Traurig, LLP;
Legal Alert/Article
October 28, 2015, previously published on October 23, 2015
For the first time in its history, the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department recently designated a bank under the Kingpin Act. The unprecedented designation of the Honduran bank, Banco Continental S.A., on Oct. 7, 2015, means that transactions with Banco...

 

HTMLSafe Harbor Invalidation Enforcement Might Commence in January 2016
Françoise Gilbert; Greenberg Traurig, LLP;
Legal Alert/Article
October 27, 2015, previously published on October 21, 2015
In early October 2015, the Court of Justice of the European Union (CJEU) in the Schrems and Facebook case, declared the EU-U.S. Safe Harbor invalid, as reported in our previous Alert. The CJEU ruling stunned many businesses and organizations throughout the world. For the past 15 years, the Safe...

 

HTMLCFPB Considering Proposal to Ban Certain Arbitration Clauses
Peter L. Cockrell, Brett M. Kitt, Gil Rudolph, J. Scott Sheehan; Greenberg Traurig, LLP;
Legal Alert/Article
October 27, 2015, previously published on October 21, 2015
On Oct. 7, the CFPB announced a proposed outline of a rule that would ban financial institutions from including in their contracts mandatory arbitration clauses that ban consumers from pursuing class action lawsuits and require institutions to report individual arbitration outcomes to the CFPB.

 

HTMLCFPB Issues Final Rule Amending HMDA Reporting Requirements
Peter L. Cockrell, Brett M. Kitt, Gil Rudolph, J. Scott Sheehan; Greenberg Traurig, LLP;
Legal Alert/Article
October 27, 2015, previously published on October 21, 2015
On Oct. 15, the CPFB issued a final rule amending the reporting requirements of the Home Mortgage Disclosure Act (HMDA). HMDA requires mortgage lenders to report certain information about the loans for which they receive applications or that they originate or purchase. Regulators and the public may...

 

HTMLCFPB Enforcement Action Against Indirect Auto Finance Company
Peter L. Cockrell, Brett M. Kitt, Gil Rudolph, J. Scott Sheehan; Greenberg Traurig, LLP;
Legal Alert/Article
October 27, 2015, previously published on October 21, 2015
On Oct. 1, the CFPB announced an enforcement action against an indirect auto finance company and its auto title lending subsidiary for alleged violations of the Fair Debt Collection Practices Act (FDCPA), the Truth in Lending Act (TILA), and the Consumer Financial Protection Act (CFPA).

 

HTMLCFPB Issues Guidance on Marketing Services Agreements and RESPA Compliance
Peter L. Cockrell, Brett M. Kitt, Gil Rudolph, J. Scott Sheehan; Greenberg Traurig, LLP;
Legal Alert/Article
October 27, 2015, previously published on October 21, 2015
On Oct. 8, the CFPB issued a compliance bulletin on the use of marketing services agreements and compliance with the Real Estate Settlement Procedures Act (RESPA). Section 8 of RESPA prohibits the payment of kickbacks and referral fees for settlement services provided in mortgage transactions. With...

 

HTMLNext Step in Iran Deal: Adoption Day requires JCPOA implementation
Kara M. Bombach, Cyril T. Brennan, Sandra K. Jorgensen; Greenberg Traurig, LLP;
Legal Alert/Article
October 23, 2015, previously published on October 21, 2015
On Oct. 18, 2015, “Adoption Day” of the Iran Joint Comprehensive Plan of Action (JCPOA), the U.S. and EU took the required steps to prepare for implementation of the JCPOA. In the U.S., the president issued a memorandum directing the Departments of State, Treasury, Commerce, and Energy...

 

HTMLNew York AG and U.S. DOL to Cooperate in Enforcing Federal and State Laws
Lynelle K. Bosworth, Eileen M. Hayes, Harold N. Iselin; Greenberg Traurig, LLP;
Legal Alert/Article
October 22, 2015, previously published on October 14, 2015
The New York State Attorney General’s Health Care Bureau (AG) and the U.S. Department of Labor Employee Benefits Security Administration (DOL) recently announced they have entered into an agreement to share information and work cooperatively to address violations of the Federal Employee...

 


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