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Adobe PDFIRS Finalizes Guidance on Rev. Rul. 81-100 Group Trusts, and Insurance Company Separate Accounts
Brenna M. Clark, Adam B. Cohen, Andrea M. Gehman, Michael A. Hepburn, Paul R. Lang; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 1, 2014, previously published on August 26, 2014
In Rev. Rul. 2014-24, scheduled for publication on September 8, 2014, the Internal Revenue Service (the Service) substantially completed its pending guidance on Rev. Rul. 81-100 group trusts by permanently authorizing the participation in group trusts of retirement plans qualified only under Puerto...

 

HTMLInsurance Industry Sweeps Retained Asset Account Doubleheader
Frederick R. Bellamy, Thomas R. Bundy, Nicholas T. Christakos, Thomas W. Curvin, Ellen M. Dunn; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 1, 2014, previously published on August 28, 2014
On August 26, the U.S. Court of Appeals for the First Circuit held in Vander Luitgaren v. Sun Life Ass. Co. of Canada, No. 13¿2090, 2014 WL 4197947 (1st Cir. Aug. 26, 2014), that an insurer, acting as a claims administrator, properly discharges its duties under the Employee Retirement Income...

 

HTMLFor Whom the Ring Tones: TCPA Litigation and the Insurance Industry
Thomas M. Byrne, Thomas W. Curvin, Ellen M. Dunn, Juan C. Garcia, Cheryl L. Haas; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
August 28, 2014, previously published on August 25, 2014
Insurance companies are increasingly the subject of Telephone Consumer Protection Act (TCPA) lawsuits. Any insurance company that communicates with its customers, job applicants, and others by phone or text using an automated telephone dialing system—or that has independent or...

 

HTMLSecond Circuit Rejects Extraterritorial Application of Dodd-Frank’s Whistleblower Anti-Retaliation Provision
Thomas R. Bundy, Peter N. Farley, Patricia A. Gorham, Cheryl L. Haas, Cynthia M. Krus; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
August 27, 2014, previously published on August 18, 2014
On August 14, the United States Court of Appeals for the Second Circuit became the first U.S. appellate court to weigh in on the extraterritorial application of the whistleblower provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. In Liu v. Siemens, A.G., the Second...

 

HTMLRecent Amendment Implements Important Changes to the Georgia Brownfield Program
James B. Jordan, Trent Myers; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
August 27, 2014, previously published on August 20, 2014
Effective on July 1, House Bill 957 (2014) (the “Amendment”) amended the Georgia Brownfield Act, O.C.G.A. § 12-8-200 et seq. (the Act). The Amendment broadens applicability of the Act, expands the pool of eligible parties under the Act, and clarifies the transferability of the...

 

HTMLFinCEN Customer Due Diligence Rule Proposal
Eric A. Arnold, Clifford E. Kirsch, Michael B. Koffler, Susan S. Krawczyk, Yasho Lahiri; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
August 27, 2014, previously published on August 19, 2014
On July 30, 2014, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules (the “Proposed Rules”) to clarify and strengthen customer due diligence requirements for banks, securities broker-dealers, mutual funds, and futures...

 

HTMLFlorida Legislature Relaxes Agency Licensing Requirements for Broker-Dealer Branch Offices Selling Insurance Products but Creates New Disclosure Requirements for Surrenders
Eric A. Arnold, Clifford E. Kirsch, Michael B. Koffler, Susan S. Krawczyk, Holly H. Smith; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
August 27, 2014, previously published on August 25, 2014
Under current Florida insurance laws, branch offices of broker-dealers selling insurance products in Florida are required to either “license” or “register” as agency branches (in addition to satisfying insurance producer licensing requirements). However, Florida recently...

 

HTMLDOL Requests Information on Brokerage Windows in Defined Contribution Plans
Brenna M. Clark, Adam B. Cohen, Andrea M. Gehman, Michael A. Hepburn, Paul R. Lang; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
August 27, 2014, previously published on August 21, 2014
On August 20, 2014, the U.S. Department of Labor (DOL) released a request for information (RFI) about the use of brokerage windows, self-directed brokerage accounts, and similar arrangements in participant-directed defined contribution plans, as part of a process to determine whether further...

 

HTMLGeorgia Coop Takes Out Ad Against EPA Rule
Sutherland Asbill Brennan LLP;
Legal Alert/Article
August 19, 2014, previously published on August 14, 2014
Oglethorpe Power was among a group of power companies that took out a full-page advertisement in the Atlanta Journal Constitution in opposition to the Environmental Protection Agency’s proposed rule curbing carbon dioxide emissions from existing power plants. The ad ran on August 10 and...

 

HTMLDOE Adopts Revised Procedures for Reviewing Applications to Export LNG to Non-FTA Nations
Sutherland Asbill Brennan LLP;
Legal Alert/Article
August 19, 2014, previously published on August 14, 2014
In a notice submitted for publication in the Federal Register tomorrow (Friday), the U.S. Department of Energy (DOE) announced that it has adopted its proposal to suspend its practice of issuing conditional decisions on applications to export LNG from the lower-48 states to nations without a Free...

 


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