Close X
Attorney Spotlight

Find out which two countries Cheryl Palmeri gets the most questions about related to International Trade in today's market? Find out more>


Close X


Search our Experience

Experience Spotlight

In June 2016, AmSurg Corp. and Envision Healthcare Holdings, Inc. (Envision) announced they have signed a definitive merger agreement pursuant to which the companies will combine in an all-stock transaction. Upon completion of the merger, which is expected to be tax-free to the shareholders of both organizations, the combined company will be named Envision Healthcare Corporation and co-headquartered in Nashville, Tennessee and Greenwood Village, Colorado. The company's common stock is expected to trade on the New York Stock Exchange under the ticker symbol: EVHC. Bass, Berry & Sims served as lead counsel on the transaction, led by Jim Jenkins. Read more.

AmSurg logo

Close X

Thought Leadership

Enter your search terms in the relevant box(es) below to search for specific Thought Leadership.
To see a recent listing of Thought Leadership, click the blue Search button below.

Thought Leadership Spotlight

Inside the FCA blogInside the FCA blog features ongoing updates related to the False Claims Act (FCA), including insight on the latest legal decisions, regulatory developments and FCA settlements. The blog provides timely updates for corporate boards, directors, compliance managers, general counsel and other parties interested in the organizational impact and legal developments stemming from issues potentially giving rise to FCA liability.

Read More >

FFIEC Warns Financial Institutions of Critical Cybersecurity Threat and Advises of Expected Response


April 11, 2014

As referenced in our prior Alert, cybersecurity is the critical and pressing concern of all companies, and particularly financial institutions. The Federal Reserve (December 2013), the Office of the Comptroller of the Currency (October 2013) and the Consumer Financial Protection Bureau (April 2012) all have  issued directives concerning management of the risks, including cybersecurity risks, involved in third party relationships. 

On April 10, 2014, in response to the recently-disclosed Heartbleed internet security flaw, the Federal Financial Institutions Examination Council (FFIEC) went further, specifically advising banks and other financial institutions that it expected them to take steps to address the vulnerability. The Heartbleed "bug" is an error in the open-source code library (OpenSSL), used to implement encryption in various websites, applications and network services, including the web portals of some financial institutions. Although reported only several days ago, the Heartbleed vulnerability apparently has existed since at least December 31, 2011. The FFIEC warned that the vulnerability might allow an attacker to impersonate bank users, steal login credentials, or gain access to internal networks.

In an accompanying alert, the FFIEC advised its governed institutions to take four steps, as appropriate, to address the Heartbleed threat: 

  1. ensure its third-party vendors that use OpenSSL are aware of the risk, and take steps to mitigate it; 
  2. monitor the status of the vendors' efforts; 
  3. upgrade its own vulnerable internal systems and services; and 
  4. follow appropriate patch management and testing practices (including those set out in existing FFIEC Examination Handbooks). 

In the alert the FFIEC also advised it expected each financial institution to take steps "as soon as possible" in response to this cybersecurity threat by upgrading its systems, and by including patches on systems and applications using OpenSSL. It also urged each institution to consider replacing private encryption keys, and to "strongly consider" requiring users and administrators to change their passwords.

Our Financial Institutions, and Data Security, Privacy and Cyberliability teams work together to provide proactive practical advice to banks and other nonbank financial institutions seeking to minimize their cyberliability exposure, and we have extensive experience advising our clients on a prompt and proper response to any discovered data breaches or other cyber incidents. 

For more information about the FFIEC's alert and press release, or any other aspect of cybersecurity risks, principles, or procedures, please contact one of the authors of this alert.

Related Professionals

Related Services


Visiting, or interacting with, this website does not constitute an attorney-client relationship. Although we are always interested in hearing from visitors to our website, we cannot accept representation on a new matter from either existing clients or new clients until we know that we do not have a conflict of interest that would prevent us from doing so. Therefore, please do not send us any information about any new matter that may involve a potential legal representation until we have confirmed that a conflict of interest does not exist and we have expressly agreed in writing to the representation. Until there is such an agreement, we will not be deemed to have given you any advice, any information you send may not be deemed privileged and confidential, and we may be able to represent adverse parties.