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12 Nov 2014, 1:56 pm
Even before his claim was denied, Black sent a letter to the company’s director of automobile claims, copying other personnel, threatening to file a complaint with the California Department of Insurance (CDI), to use “social media to facilitate a viral consumer brand awareness campaign about Allianz’s history of ‘evil and corruption’ in a global boycott of Allianz products and stock until [Fireman's Fund] corrects its conduct,” and to pursue civil… [read post]
28 Oct 2014, 6:34 am
Specifically, CMS will discuss data collection and submission information for outcome measures related to hospital-onset methicillin-resistant Staphylococcus aureus (MRSA) bacteremia and Clostridium difficile infection (CDI), which IRF providers are required to report to CMS beginning January 1, 2015. [read post]
15 Oct 2014, 10:37 pm
Today's post is shared from daviddepaolo.blogspot.com/A lot of employers try to lower their workers' compensation costs by fudging the numbers on their payroll reports, or paying workers "under the table," or misclassifying their jobs.Some employees take advantage of the no-fault design of the system to make claims that didn't occur, or inflate the severity of the claim.And there are some people on the claims side that try to "meet the numbers" by denying, delaying… [read post]
15 Oct 2014, 4:54 am
The CDI data does not have an estimated loss for the remaining 47 of those convictions, but if extrapolated against the "known" losses, then the total for that time period is $17.5 million of losses attributable to employers.$1.3 million out of that "known" $8 million is attributed to false claims filed by 67 of 73 individuals. [read post]
8 Oct 2014, 7:13 am
Also on the topic of Rule 506(c), some data about who is using the new rules, from Morrison & Foerster A blog post from Cooley on how a new SEC CDI on how companies can use computer IP addresses to confirm that an offering is intrastate may not be workable. [read post]
8 Oct 2014, 6:06 am
Sources: SEC staff issues CDI regarding use of the internet in connection with intrastate offerings — how feasible is it? [read post]
8 Oct 2014, 5:00 am
As Steve Quinlivan notes in this blog, a new Corp Fin CDI 141.05 (Securities Act Rules) indicates that companies may use IP addresses to effectively limit their offers to particular states or territories to qualify for Rule 147’s intrastate offering exemption: In a new CDI, the SEC indicates it may be possible to use IP addresses to control internet communications so that offers are made only in one state and qualify for the intrastate exemption under Rule 147. [read post]
2 Oct 2014, 11:55 am
Non-participating providers’ rights to sue in a reimbursement dispute, again, depend on whether the patient they rendered services to has a Department of Mental Health Care (DMHC) or California Department of Insurance (CDI) regulated plan. [read post]
29 Sep 2014, 10:02 pm
“Antibiotic exposure remains the most important risk factor for CDI. [read post]
4 Sep 2014, 4:32 am
Principles-Based Determinations Here’s a guest blog by Stan Keller of Edwards Wildman: Recently, Professor Jay Brown wrote an article criticizing Corp Fin for expanding and weakening the safe harbor for verifying accredited investor status based on income under Rule 506(c)(2)(ii)(A) when it issued CDI 260.35 in response to the situation where the relevant IRS forms are not yet available at the time of verification. [read post]
3 Sep 2014, 10:43 pm
I had the pleasure of attending the 2014 IHL Dialogs last week in lovely Chautauqua, NY. [read post]
14 Aug 2014, 7:40 am
CDI is developing a conceptual and practical framework aimed at practitioners working on accountability in the CAC context. [read post]
Crowdfunding Right Now (Fund Model, Broker-Dealer Model, Lending Platforms and Intrastate Offerings)
6 Aug 2014, 10:49 am
The new CDIs provided guidance and clarification with respect to the recent numerous state crowdfunding exemptions that are rapidly increasing in number. [read post]
28 Jul 2014, 10:53 am
The SEC’s Compliance and Disclosure Interpretations from April 11, 2014 (“CDIs”) highlights some of the challenges of intrastate offerings. [read post]
24 Jul 2014, 3:42 am
As the result of a collaborative effort between Ginsberg Jacobs’ Anthony Zeoli, Crowdcheck and Seyfarth Shaw’s Georgia Quinn, here is a comparative summary chart where you can go to compare all of the enacted instrastate crowdfunding exemptions side-by-side – and here’s a chart with the proposed intrastate crowdfunding exemptions… More on “New Intrastate Offering Exemptions: Not Useful” Back in April when Corp Fin issued 3 CDIs about the intrastate… [read post]
23 Jul 2014, 4:38 am
Note that Corp Fin has issued Reg FD CDI Question 101.11 which clarifies that directors are not prohibited from speaking privately with shareholders. [read post]
22 Jul 2014, 2:15 pm
The SEC attempted to provide some clarification in this area by the issuance of six new Compliance and Disclosure Interpretations (CDI’s): CDI 255.48 relates to the exchange rate to be used to determine an investor’s annual income when it is not reported in U.S. dollars. [read post]
7 Jul 2014, 4:03 am
On Thursday, just a week after SIFMA issued guidance on the topic, Corp Fin issued these 6 new CDIs relating to Regulation D – in particular, verification of accredited investors: 1. [read post]
2 Jul 2014, 5:30 am
CDI detectives and United States Postal Service Office of Inspector General Special Agents conducted a joint investigation that led to Buckner’s arrest. [read post]
26 May 2014, 1:10 am
A lui seul, le volume, inégalé dans l’histoire de la CDI, du produit final du travail de la Commission (le Guide comporte 660 pages) témoigne de l’abondance et de l’extrême diversité de la pratique des réserves ainsi que de l’amplitude des difficultés que cette pratique soulève sur le terrain de la technique juridique. [read post]
