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DoD's New Year's Gift: More Time to Meet Cyber Safeguarding Requirements

Client Alert | less than 1 min read | 12.30.15

On December 30, DoD issued an interim rule amending the DFARS Safeguarding Rule in several respects, including to provide contractors up to December 31, 2017, to comply with the security control requirements identified in DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, and detailed in NIST Special Publication 800-171, Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations. Despite the additional time to comply, within 30 days of contract award, contractors must still notify the DoD Chief Information Officer of any NIST SP 800-171 security requirements not yet implemented.

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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....