Tag Archives: Arrangements

Senators Renew Pressure on POD Arrangements

In a March 19 letter to CMS and HHS-OIG, Senators Chuck Grassley (R-IA) and Ron Wyden (D-OR) continued their oversight efforts regarding physician-owned distributorship (POD) relationships by raising questions about US Sunshine compliance by PODs. PODs involve the ownership of … Continue reading

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The Securities and Exchange Commission and the UK Financial Conduct Authority Sign Updated Supervisory Cooperation Arrangements

The Securities and Exchange Commission and the United Kingdom (UK) Financial Conduct Authority (FCA) have today reaffirmed their commitment to continue close cooperation and information sharing in the event of the UK’s withdrawal from the European Union (EU).As evidence of … Continue reading

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Reviewing Compensation Arrangements for Employees Subject to U.S. Income Tax Before Year-End Could Avoid Costly Tax Penalties

We have written about this in the past [here], but the message bears repeating each year. It is easy to overlook that employment agreements, change-in-control agreements, and severance agreements with U.S. taxpayers frequently contain provisions that subject them to U.S. Internal … Continue reading

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CPMI – IOSCO consult on governance arrangements for critical OTC derivatives data elements

On 16 August 2018, the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) published a consultative report, Governance arrangements for critical over-the-counter (OTC) derivatives data elements (other than UTI and UPI). The CPMI … Continue reading

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HUD Audits Claim First Magnus Marketing And Volume-Based Incentive Arrangements Violated RESPA

HUDs Office of Inspector General (OIG) recently completed audit reports with respect to marketing, noncompetition and volume-based incentive arrangements entered into by First Magnus Financial Corporation, and concluded that these arrangements violated the Real Estate Settlement Procedures Act ("RESPA"). According … Continue reading

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