Publication - 08/13/2012

New FTC Standards for Data Security?

Data Security Client Alert

When the Federal Trade Commission, in conjunction with the White House, promulgated its Consumer Privacy Bill of Rights in February 2012, one of the more intriguing considerations was that the FTC appeared to be setting up a matrix by which a company’s voluntary decision to adopt that matrix could become the basis for an FTC enforcement action. Now, after several months, it should be back at the forefront of data security considerations for U.S. businesses.

Earlier this summer, the FTC used that matrix in authorizing a federal action against Wyndham Worldwide Corp. and three of its subsidiaries – a development that highlights a possible change in stance from FTC Commissioner J. Thomas Rosch and illustrates for businesses the importance of developing detailed data/privacy policies.

Click on the PDF link above to view the full alert.

Another Warning to Mind the Non-GAAP

Client Alert
Elizabeth A. Diffley

By Elizabeth A. Diffley As we have previously reported, over the past few months, SEC officials and numerous other observers have voiced concern about the pervasive and, perhaps abusive, use of non-GAAP financial measures by public companies.  Continuing on that theme, during a panel presentation at the Garrett Corporate and Securities Law Institute held at Northwestern University’s Pritzker School of Law, Mark Kronforst, Associate Director of the SEC’s Office of the Chie...

Overcoming Compliance II

Reactions
Thomas M. Dawson, Joseph L. Seiler III

Socially Responsible Investing in ERISA Plans: The Legal Perspective

Institutional Investor: Foundation & Endowment Money Management
Bruce L. Ashton

Institutional Investor: Foundation & Endowment Money Management

IRS Denies Tax Exemption to Commercial ACO

Health Care Insight
Matthew Amodeo, Taylor Romigh Harrison, Linda S. Moroney, T.J. Sullivan

On April 8, 2016, the IRS released a final adverse exemption determination with respect to an accountable care organization (ACO) formed by an unnamed nonprofit health care system.

Section 201 Safeguard Petition Filed Against Primary Aluminum Could Impact Sourcing

Client Alert
Richard P. Ferrin, Douglas J. Heffner

On April 18, the United Steelworkers union filed a Section 201 “safeguards” petition regarding primary, unwrought aluminum. This case could impact purchasers of primary, unwrought aluminum (such as billets, hollow billets, ingots, sows, and tees) from non-U.S. sources by increasing the prices of these products, decreasing availability, or both.