Keith Mullen

After 30+ years of representing large and small financial institutions across the US, my focus now is managing legal workflow and  creating tools to lift legal content out of the traditional, manual legal process into a rich, self-service process – a transformed process with rich collaboration, communication and information gathering.  A frequent speaker and writer, Keith is a member of the College of the State Bar of Texas, the Association of Life Insurance Counsel, the American College of Mortgage Attorneys, and the Mortgage Bankers Association. To learn more about Keith, visit the Firm’s website.

Latest Articles

On August 21, 2018, the IRS issued Notice 2018-68, which provides initial guidance on two aspects of the amendments to Section 162(m) of the Internal Revenue Code made by the Tax Cuts and Jobs Act: how to identify the expanded group of employees who are covered by new Section 162(m); and how a plan or agreement can qualify as grandfathered from new Section 162(m). This memorandum summarizes this guidance, as well as the additional…
On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (TCJA), which generally went into effect for tax years beginning on or after January 1, 2018.  The TCJA provisions affecting executive compensation (for example, the elimination of the performance-based compensation exception to Section 162(m) of the Internal Revenue Code) have received signification attention, but the TCJA also has meaningful implications for broad-based employee benefit plans and programs. A memorandum that provides an…
On April 2, 2015, following the controversy stemming from the recent signing of the Indiana Religious Freedom Restoration Act (IRFRA), Indiana Governor Mike Pence signed into law an amendment to the IRFRA. The amendment states that the Act may not be used to discriminate in the providing of services, facilities, use of public accommodations, goods, employment, or housing on the basis of race, color, religion, ancestry, age, national origin, disability, sex, sexual orientation, gender identity,…
In meetings with senior executives and their in-house counsel, I hear this consistent cry: due to ever-increasing regulations, costs associated with compliance are soaring at commercial banks and at financial institutions that own banks (such as life insurance companies).  As a result, “regulatory cost collaboration” is becoming a key strategy for financial institutions with their key vendors.  It is a strategy that overlooks a very familiar and expense vendor: lawyers.   This omission will not…
I’m back. Back to blogging. Home here at L360. Several years ago, Kevin O’Keefe or Tom Mighell (one of them) commented that the majority of legal blogs last less than a year. Clearly, I’m one of them on quiting. It just took me longer to quit. I stopped regularly blogging after 4 years (from September, 2008 until October 2012), and after over 420 blog entries. Always focusing on commercial finance, I started blogging on distressed…
Earlier this week, the General Counsel of the National Labor Relations Board (NLRB), Richard F. Griffin, authorized the issuance of multiple complaints which include allegations that a franchisor, McDonald’s, USA, LLC, could be liable as a joint employer with its franchisees for violations of the National Labor Relations Act (NLRA). The text of the General Counsel’s authorization is available here.…
Over the last few weeks, I’ve commented on the new version of the OCC’s Commercial Real Estate Lending Handbook (I give it a gentlemen’s C); and I listed a few legal topics that deserve some guidance from the OCC. “Guidance” could even merely be a list of important topics (ending with a warning that the list is NOT an all-inclusive list). I expect legal issues to be identified and put on the “check…