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HTMLIRS Issues Final Rules on Mid-Year Suspension or Reduction of Safe Harbor 401(k) Plan Nonelective and Matching Contributions
Troutman Sanders LLP;
Legal Alert/Article
November 22, 2013, previously published on November 21, 2013
On November 14, 2013, the Internal Revenue Service (IRS) issued final regulations addressing an employer's ability to reduce or suspend safe harbor nonelective and matching contributions to 401(k) plans in the middle of a plan year. The regulations soften the requirements for suspension of safe...

 

HTMLNERC Completes Grid Security Exercise; FERC Accepts NERC Compliance Filing on Planning Criteria
Peter S. Glaser, Kevin C. Greene, Daniel L. Larcamp, Clifford S. Sikora, Lara L. Skidmore; Troutman Sanders LLP;
Legal Alert/Article
November 21, 2013, previously published on November 18, 2013
On November 13 and 14, 2013, the North American Electric Reliability Corporation (‘NERC”) completed its international biennial Grid Security Exercise (“GridEx”) - a series of exercises that simulate cyber and physical attacks on the bulk power system. The simulated...

 

HTMLFERC and CA Air Resources Board to Share Information Related to Market Monitoring and Oversight Activities
Peter S. Glaser, Kevin C. Greene, Daniel L. Larcamp, Clifford S. Sikora, Lara L. Skidmore; Troutman Sanders LLP;
Legal Alert/Article
November 21, 2013, previously published on November 18, 2013
On October 21, 2013, FERC and the California Air Resources Board (“CARB”) jointly executed a Memorandum of Understanding (the “Memorandum”), setting out a process for inter-agency cooperation in the dissemination of certain information. The Memorandum is non-binding and...

 

HTMLFERC Approves ISO-NE Proposal to Increase Nonperformance Penalties in Forward Capacity Market
Peter S. Glaser, Kevin C. Greene, Daniel L. Larcamp, Clifford S. Sikora, Lara L. Skidmore; Troutman Sanders LLP;
Legal Alert/Article
November 14, 2013, previously published on November 11, 2013
On Friday, November 1, FERC approved changes to ISO New England, Inc.’s (“ISO-NE”) Transmission, Markets and Services Tariff expanding the instances in which ISO-NE can penalize resources that have capacity supply obligations and are completely or partially unavailable during...

 

HTMLFERC Approves Revisions to CAISO Bid Cost Recovery Rules
Peter S. Glaser, Kevin C. Greene, Daniel L. Larcamp, Clifford S. Sikora, Lara L. Skidmore; Troutman Sanders LLP;
Legal Alert/Article
November 13, 2013, previously published on November 11, 2013
On October 29, 2013, FERC approved revisions to the California Independent System Operator Corporation’s (“CAISO”) tariff to modify its generator bid cost recovery rules. The revisions will allow for the inclusion of additional categories of costs in the bid cost recovery and...

 

HTMLOCC Guidance is Latest in Heightened Regulatory Scrutiny of Vendor Management
Jacob "Jake" A. Lutz, Matthew W. Marzetti, James W. Stevens; Troutman Sanders LLP;
Legal Alert/Article
November 11, 2013, previously published on November 5, 2013
On October 30, 2013, the Office of the Comptroller of the Currency (the “OCC”) issued updated guidance for national banks and federal savings associations, including community banks, on assessing and managing risks associated with third-party relationships. This is the latest step in a...

 

HTMLIRS Modifies “Use It or Lose It” Rule for Health FSAs
Jeffery R. Banish, Josh F. Norris, Evelyn Small Traub; Troutman Sanders LLP;
Legal Alert/Article
November 8, 2013, previously published on November 7, 2013
The IRS has issued Notice 2013-71 announcing a change in the “use it or lose it” rule for healthcare flexible spending accounts (Health FSAs). The “use it or lose it” rule generally requires unused amounts in the participant’s Health FSA at the end of the plan year to...

 

HTMLMajor Development: CFPB Issues Advance Notice of Proposed Rulemaking for Debt Collectors
Troutman Sanders LLP;
Legal Alert/Article
November 8, 2013, previously published on November 7, 2013
On November 6, 2013, the Consumer Financial Protection Bureau (CFPB) issued an Advance Notice of Proposed Rulemaking (ANPR) directed at the debt collection industry. The CFPB is seeking comments, data and information from the public regarding a variety of rules proposed to govern collection...

 

HTMLYear-End Checklist for Plan Sponsors of Retirement and Group Health Plans
Jonathan A. Kenter, Adam M. Meehan, Evelyn Small Traub; Troutman Sanders LLP;
Legal Alert/Article
November 6, 2013, previously published on November 1, 2013
Over the next few months, employers and plan sponsors will probably focus most of their attention on the changes mandated by the Patient Protection and Affordable Care Act, as amended (ACA), for health plans, and the effect of U.S v. Windsor on both retirement and group health plans. With all the...

 

HTMLDepartment of Energy Inspector General Audit Report Finds That Utility Data is Vulnerable to Cyber-Threats
Peter S. Glaser, Kevin C. Greene, Daniel L. Larcamp, Clifford S. Sikora, Lara L. Skidmore; Troutman Sanders LLP;
Legal Alert/Article
November 6, 2013, previously published on November 1, 2013
On October 23, 2013, the Inspector General of the Department of Energy (“DOE IG”) released an audit report evaluating FERC’s Unclassified Cyber Security Program. In the audit, the DOE IG concluded that despite FERC’s progress in improving its internal processes related to...

 


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