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DoD Previews Final Cybersecurity Maturity Model Certification with Revision 0.7

Client Alert | 1 min read | 12.17.19

The Department of Defense (DoD) recently released another revision to its Cybersecurity Maturity Model Certification (CMMC) that, starting next year, independent auditors will use to certify contractor compliance with DoD cybersecurity requirements. Most notably, Revision 0.7 previews the requirements for cybersecurity maturity Levels 4 and 5. Moving beyond the cyber hygiene requirements of Levels 1 through 3, Levels 4 and 5 require even more robust cybersecurity programs capable of addressing the dynamic threats posed by advanced persistent threats (APTs). These two highest levels of certification also implement the enhanced security requirements documented in NIST SP 800-171B, which remains in draft form.

The DoD is expected to announce the final CMMC in January of next year and begin introducing “go/no-go” certification requirements in solicitations as early as June 2020.


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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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