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Administration To Begin E-Verify Enforcement On September 8, 2009

Client Alert | 1 min read | 07.15.09

The Obama administration has completed its evaluation of the E-Verify rule and will begin enforcing compliance with the rule on September 8, 2009; as a result, federal contractors and subcontractors will be required to use Homeland Security’s E-Verify system to verify the employment eligibility of all new hires in the U.S. and all employees working in the U.S. on federal contracts valued at $100,000 and subcontracts valued greater than $3,000. However, the future of E-Verify and the obligations of contractors remain uncertain for two reasons: (1) litigation challenging the E-Verify rule, which had been stayed pending the administration’s evaluation, will likely now move forward; and (2) the Senate has approved an amendment to the 2010 Homeland Security spending bill that would expand E-Verify to apply to all existing employees, and not just new hires or those employees working on federal contracts at the thresholds listed above.

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Client Alert | 7 min read | 09.02.26

OCC and FDIC Redefine “Unsafe or Unsound Practices”: The New Supervisory Framework for Banks

On August 27, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) jointly issued a final rule that, for the first time, gives the term “unsafe or unsound practice” a binding regulatory definition.[1] With it came a uniform standard for Matters Requiring Attention (MRAs) and revised OCC examination manuals.[2]The Federal Reserve did not join the rulemaking, but has adopted comparable standards through guidance. What that means for holding companies and state-chartered institutions is addressed below.[3] The regulation takes effect November 2, 2026, and the revised OCC examination manuals took effect upon their issuance on August 27....

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