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Results: 1-10 of 130

Statutorily Disqualified? FINRA Says “Deal With It”
  • Ulmer & Berne LLP
  • USA
  • November 18 2016

It is a nasty thing when one becomes statutorily disqualified. It means either leaving the industry, permanently, or having to file an MC-400 and


Looking For A Silver Lining: Post-Election Thoughts On The SEC
  • Ulmer & Berne LLP
  • USA
  • November 11 2016

Wednesday morning marked the confluence of two events. First, like the rest of the world, I awoke to the reality of the results of the presidential


When It Comes To Churning, FINRA Knows What’s Best For Investors
  • Ulmer & Berne LLP
  • USA
  • November 1 2016

Since I first started practicing law back in the 1980s, customer complaints against brokers have often involved allegations of “churning,” which is


It’s Official: The SEC Has No Sense Of Humor
  • Ulmer & Berne LLP
  • USA
  • October 17 2016

One of my colleagues and I were busy the last two week defending an SEC administrative proceeding out-of-town, so I have not had much chance to blog


Frequently Asked Questions About FINRA Rule 8210
  • Ulmer & Berne LLP
  • USA
  • October 3 2016

As readers of this Blog know, Rule 8210 is a favorite subject of mine to complain about, particularly the frightening vigor with which FINRA


A Settlement Agreement With FINRA (Or So You Thought)
  • Ulmer & Berne LLP
  • USA
  • September 27 2016

In OHO Order 16-26, a Hearing Officer confirmed what those uninitiated to FINRA’s Disciplinary process likely would not even suspect: an agreement to


The Math of Mark-UpsDowns
  • Ulmer & Berne LLP
  • USA
  • September 14 2016

It is well settled - indeed, it is a FINRA Rule - that broker-dealers need to charge "fair" prices when they buy securities from, and sell securities


Data Breach Response May Help Support Plaintiffs’ Standing, Says the 6th Circuit
  • Ulmer & Berne LLP
  • USA
  • September 12 2016

The U.S. Sixth Circuit Court of Appeals recently joined a minority of courts in holding that the compromise of personal information through a


Pick Your Poison: Given What A Jury Can Do, Is Arbitration Really That Bad?
  • Ulmer & Berne LLP
  • USA
  • September 1 2016

Some of my clients simply cannot enough bad things about the arbitration process. It is expensive. It is unfair. There's no industry panelist anymore


Advertising Case Loss Reveals Limits To FINRA’s Jurisdiction Over Outside Business Activities
  • Ulmer & Berne LLP
  • USA
  • August 30 2016

It is a simple fact that a broker-dealer has no obligation to supervise a disclosed outside business activity. How do I know? FINRA has said so. This