Searching Content indexed under Fiscal & Monetary Policy by WilmerHale ordered by Published Date Descending.
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Federal Civil Penalties Set To Increase Significantly, Many Present Retroactivity Concerns
Over the past several months, many federal agencies have adopted rules significantly increasing the maximum civil monetary penalties ("CMPs") they can potentially impose. The increased penalty amounts were adopted in response to recent legislation from Congress requiring that federal agencies make adjustments to "catch up" with inflation. The catch up adjustments allow agencies to increase their penalty amounts by as much as 150% of their November 2, 2015 values. In addition, agencies must make
United States
16 Sep 2016
OCC Revises CMP Policy
For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal branches of foreign banks, and their service providers and institution affiliated parties (IAP).
United States
15 Mar 2016
OCC Proposes Recovery Plans For Large Banks
On December 17, 2015, the Office of the Comptroller of the Currency (OCC) proposed guidelines establishing enforceable standards for recovery planning by certain large national banks, ..
United States
23 Dec 2015
Energy, Infrastructure Permitting Improvement Legislation Signed By The President
The Highway Authorization Act signed into law by President Obama last Friday, December 4, includes an important set of reforms for streamlining the federal permitting process for infrastructure projects in a broad range of sectors, ..
United States
7 Dec 2015
Administration Announces New Mitigation Policies
This afternoon, the Administration issued two policies intended to encourage private investment in natural resource conservation and to facilitate application of the mitigation hierarchy—avoiding, minimizing and compensating project impacts.
United States
4 Nov 2015
Department Of Defense Issues Final Rule Expanding Military Lending Act To Credit Cards And Other Consumer Lending Products
On July 21, 2015, the U.S. Department of Defense ("DOD") announced the final rule amending the Military Lending Act's ("MLA") implementing regulations.
United States
23 Jul 2015
Contribution Caution: Mitigating Risks From Pay-To-Play
With the record-breaking campaign expenditures of the 2014 midterm elections behind us, and the 2016 campaign cycle already heating up, this is an ideal moment for investment advisers (including advisers to venture capital funds and certain private equity and hedge funds) to ensure that they have mechanisms in place to verify compliance with the U.S. Securities and Exchange Commission’s pay-to-play rule.
United States
7 Apr 2015
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