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Welcome to the Center for Regulatory Strategies blog. We developed this platform to promote the sharing of insights, experiences and perspectives on the latest regulatory developments and trends in the financial services, energy and resources, life sciences and health care industries.

The Center for Regulatory Strategies delivers detailed and thoughtful insights from a powerful team of former regulators, industry specialists and trusted business advisers. We encourage you to participate in the discussion with our Center for Regulatory Strategies leadership team and your peers.

Featured insights

New! CMS offers partial payment for Medicare denials; hospitals should eye options carefully 
The global settlement offer announced by the CMS on August 29. What does this mean for acute care and critical access hospitals?

New! Heightened risk requirements: OCC defines “strong,” now banks must get there 
On September 2, 2014, the OCC finalized new standards that formalize “heightened expectations” for risk governance on the banks over $50 billion. What are some key elements of which banks should be aware?

New! Liquidity ratio rule becomes final; some relief, but plenty of work ahead
On September 3, 2014, a trio of U.S. regulatory agencies – the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve System – issued the final version of the Liquidity Coverage Rule (LCR) that was first circulated in late 2013.

Financial Services

New! Heightened risk requirements: OCC defines “strong,” now banks must get there 
David Wilson, Senior advisor, Deloitte & Touche LLP
On September 2, 2014, the OCC finalized new standards that formalize “heightened expectations” for risk governance on the banks over $50 billion. What are some key elements of which banks should be aware?

Dodd-Frank four years later
David Wright, Managing Director, Deloitte & Touche LLP
The Dodd–Frank Wall Street Reform and Consumer Protection Act was a direct response to the financial downturn, and was specifically designed to prevent a similar crisis from happening again. So how are things going so far?

The Securities and Exchange Commission Reforms Money Market Rules
Tim O’Sullivan, Director, Deloitte & Touche LLP
On July 23, 2014, the Securities and Exchange Commission (SEC) adopted amendments to the rules that govern money market mutual funds. This blog explores some key implications.

Fed FAQs for FBOs
Irena Gecas-McCarthy, Principal, Deloitte & Touche LLP
On June 26, 2014, the Federal Reserve (Fed) published answers to a list of frequently asked questions (FAQs) from foreign banking organizations (FBOs) that face enhanced prudential standards.

Regulators propose new reporting requirements for home mortgages
John Graetz, Principal, Deloitte & Touche LLP
Tamara Milliken, Director, Deloitte & Touche LLP
The Consumer Financial Protection Bureau (CFPB) proposed amendments to the Home Mortgage Disclosure Act (HMDA). This blog post summarizes and groups the key changes into five broad categories.

Eighth annual regulatory & risk update
Thomas Rollauer, Executive Director, Center for Regulatory Strategies
Deloitte & Touche LLP

This 4-part blog series provides a general overview of the plenary keynote address, plenary panel discussion, banking breakout and securities breakout and highlights some of the leading practices discussed.

Regulatory Liaison Office: Savvy investment or basic necessity?
Peter Reynolds, Director, Deloitte & Touche LLP
In today's challenging regulatory environment, a new corporate role of regulatory liaison with staff to support it is emerging to provide a central point of contact for the regulatory community.

Four observations on how financial institutions are "getting to strong"
Deborah Bailey, Director, Governance, Regulatory & Risk Strategies
Deloitte & Touche LLP

As you know, regulators are pushing banks, systemically important financial institutions (SIFIs) and other organizations to raise their risk management programs to a "strong" rating.

Life Sciences and Health Care

New! CMS offers partial payment for Medicare denials; hospitals should eye options carefully 
Kelly Sauders, Partner, Deloitte & Touche LLP
Nancy Perilstein, Senior Manager, Deloitte & Touche LLP
The global settlement offer announced by the CMS on August 29. What does this mean for acute care and critical access hospitals?

HIX compliance for health plans
Ian Waxman, Senior Manager, Deloitte & Touche LLP
New structures come with new rules, and health insurance exchanges (HIX) are no exception. That said, health insurers need to know more than the new rules — they need to understand the protocols and priorities regulators intend to use in building out this new regulatory regime.

Preparing for FDA social media guideline implementation
Seth Whitelaw, Director, Deloitte & Touche LLP
The FDA has released new guidance regarding utilization of social media for advertising and promotion of pharmaceuticals and medical devices. Read takeaways from this long-awaited guidance.

Hot off the press: FDA strategic priorities
Seth Whitelaw, Director, Deloitte & Touche LLP
Just before the July 4th weekend, the U.S. Food and Drug Administration (FDA) released a draft of its strategic priorities for the next four years. In case you were busy celebrating the holiday and didn’t have a chance to read through all forty pages of the report, here is a quick recap of some of the goals the FDA will be focusing on between now and 2018.

Follow then lead
Kelly Sauders, Partner, Deloitte & Touche LLP
Retailers expanding into health and wellness should start by looking to the health care industry for initial inspiration and insight.

Physician arrangements
Kelly Sauders, Partner, Deloitte & Touche LLP
As a result of entering into contractual agreements with non-hospital employed physicians and other ancillary providers, hospitals are dealing with increased regulatory scrutiny.

Making progress on health insurance exchanges without definitive guidance
Kelly Sauders, Partner, Deloitte & Touche LLP
Health plans are waiting for CMS (The Centers for Medicare and Medicaid Services) to provide detailed requirements and guidance about participating in federal health insurance exchanges. In the meantime, we believe their leading bet is to refer to the managed care manuals for Medicare Part C and D.

Risks and challenges of expanded retail pharmacy offerings
Kelly Sauders, Partner, Deloitte & Touche LLP
Many retailers are considering expanding their pharmacy offerings to tap into bigger margins and new revenue sources.

Sunshine Act compliance efforts continue to chug along
Seth Whitelaw, Director, Deloitte & Touche LLP
The Physician Payment Sunshine Act (“Sunshine Act”) has a lot of moving parts and compliance — is without doubt — a complex undertaking. As the March 31st reporting deadline looms large, we have seen that complexity manifest itself in the communications coming out of the Centers for Medicare and Medicaid Services(“CMS”).

Congress boosts funding to improve 340B program integrity
Ray Albertina, Director, Deloitte & Touche LLP
Marcy Imada, Principal, Deloitte & Touche LLP
Congress recently appropriated an additional $6 million to enable the Health Resources and Services Administration (HRSA) and Office of Pharmacy Affairs (OPA) to expand existing program integrity efforts for 340B drug pricing.

CMS proposes significant policy changes for the 2015 Medicare Advantage and Prescription Drug programs
Kelly Sauders, Partner, Deloitte & Touche LLP
There is a lot of information to wade through and the new provisions could affect many different parts of the business — from costs and budgeting to operational processes and resource planning — so it makes sense to get started right away.

Medicare claims at risk
Kelly Sauders, Partner, Deloitte & Touche LLP
The Centers for Medicare and Medicaid Services (CMS) have now started to implement their long-anticipated Risk Adjustment Data Validation (RADV) audits. How can this impact health plans?

Getting ready for UDI in medical devices
Larry Spears, Director, Deloitte & Touche LLP
On September 24, 2013, the U.S. Food and Drug Administration (FDA), published its long-anticipated unique device identification (UDI) regulation. There's a lot to do and the clock is ticking. It's time to get started.

Responding to medicare's new short stay rules
Kelly Sauders, Partner, Deloitte & Touche LLP
The Centers for Medicare & Medicaid Services' (CMS) new '2 midnight rule' has tremendous financial and operational implications and should be addressed immediately.

Four actions you can still take to begin Sunshine Act compliance
Seth Whitelaw, Director, Deloitte & Touche LLP
August 1st has come and gone and the Physician Payment Sunshine Act ("Sunshine Act") has now gone live. Have you started tracking payments and other "transfers of value" to physicians and teaching hospitals? If not, I have two words for you: Don't panic.

Energy and Resources

Front and center 
Paul Campbell, Principal, Deloitte & Touche LLP
What are energy companies doing to address their compliance challenges and how can they stay ahead of regulatory trends and requirements without creating unnecessary drag on the business? This blog entry provides an overview of the Fifth Annual Energy Regulatory Compliance Survey results.

Linking pay to regulatory compliance in the energy industry
Paul Campbell, Principal, Deloitte & Touche LLP
As regulators in the energy industry expand their role and impact, a growing number of energy companies are warming up to the idea of explicitly tying executive and employee compensation to key performance indicators (KPIs).

Cross-Industry

Highlights from the 2014 compliance week conference
Nicole Sandford, Partner
Deloitte & Touche LLP

Deloitte recently presented at the 2014 Compliance Week Conference in Washington, D.C., which drew top executives and compliance professionals from leading companies across a wide range of industries. Explore hot topics discussed during the conference.

2014 Compliance trends survey report 
Thomas Rollauer, Executive Director, Center for Regulatory Strategies
Deloitte & Touche LLP

The annual Deloitte and Compliance Week survey results found some level of improvement in addressing compliance risks; however, there is still a burning need for organizations to improve how they handle their compliance activities.

Top regulatory trends for 2014
Thomas Rollauer, Executive Director, Center for Regulatory Strategies
Deloitte & Touche LLP

The Deloitte Center for Regulatory Strategies is producing a series of reports that discuss the top regulatory trends for 2014 in five key industries: energy, banking, securities, insurance and life sciences.

New survey: Companies advance their compliance programs, but a long road remains
Thomas Rollauer, Executive Director, Center for Regulatory Strategies
Deloitte & Touche LLP

In a joint effort with Compliance Week, our newly released In focus: 2013 Compliance Trends Survey shows the progress that companies worldwide have made in building and managing their compliance programs — and it's a mixed bag.