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How does Jessie Zeigler anticipate the intersection of privacy and smart technology will impact the future of litigation? Find out more>

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Primary Care Providers Win Challenge of CMS Interpretation of Enhanced Payment Law

With the help and support of the Tennessee Medical Association, 21 Tennessee physicians of underserved communities joined together and retained Bass, Berry & Sims to file suit against the Centers for Medicare & Medicaid Services to stop improper collection efforts. Our team, led by David King, was successful in halting efforts to recoup TennCare payments that were used legitimately to expand services in communities that needed them. Read more

Tennessee Medical Association & Bass, Berry & Sims

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Thought Leadership

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Thought Leadership Spotlight

GDPR Top 5 Actions You Should Take Now

The EU's General Data Protection Regulation (GDPR) went into effect on May 25th. As most organizations are aware, the GDPR applies not only to EU businesses but also many companies in the U.S. While the deadline is quickly approaching, most organizations are still grappling with the implications of the regulation on their business. Even if your readiness efforts are behind the curve, the GDPR Top 5 Actions You Should Take NOW will help you begin your efforts towards compliance and help mitigate your organization's risk in the short-term.

Click here to download the checklist.

OCC: Cybersecurity Top Supervisory Priority

Publications

August 20, 2015

Consistent with the Office of the Comptroller of the Currency's (OCC) Annual Report for Fiscal Year 2014 that listed cybersecurity as a major risk to banks' safety and soundness, the OCC's Semiannual Risk Perspective for Spring 2015 also identified cybersecurity as a supervisory priority for its examinations. In the 2015 report, the OCC highlighted the importance of an "increased focus of cybersecurity at third-party technology service providers" by its examiners.

OCC regulations presently provide that regulated financial institutions must exercise appropriate and effective oversight of their service providers. Banks cannot avoid cybersecurity compliance by outsourcing various operations to technology providers. The OCC concludes that banks must require their technology providers to maintain appropriate cybersecurity programs designed to detect and respond to cyber-attacks to avoid risk.

Further, OCC guidelines state that banks can require service providers, by contract, to have policies and procedures that will detect cyber-attacks consistent with those required of the banks themselves. Given the difficulty that banks historically have had in including such terms in contracts with providers, banks are facing a perplexing problem of how they can satisfy themselves and the OCC's cybersecurity requirements.

If you have any questions about the content of this Alert, please contact one of the authors listed above or any member of our Data Security & Privacy team.


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