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New Ohio Requirements for Physician Prescriptions Without Physical Examination
  • Ulmer & Berne LLP
  • USA
  • April 24 2017

Ulmer Client Alert Topic: Health Care Are you an Ohio physician who may from time to time provide a prescription to a patient without personally


When It Comes To Testifying To The SEC, Providing Alternative Facts Can Be A Bad Idea
  • Ulmer & Berne LLP
  • USA
  • April 22 2017

At the beginning of most FINRA OTRs, the examiner reads from a script of sorts, outlining some of the basic rules governing the proceeding. One of the


FINRA Tweaks The Sanction Guidelines Again And - Guess What? - It Wasn’t To Make Them Gentler
  • Ulmer & Berne LLP
  • USA
  • April 13 2017

Remember a few weeks ago? Remember I blogged about Robert Cook, FINRA’s new CEO? And how he was saying all the right things about FINRA perhaps being


Some Amusing OHO Decisions
  • Ulmer & Berne LLP
  • USA
  • April 12 2017

As a former member of FINRA Enforcement’s Litigation Department and a current practitioner in FINRA regulatory matters, I have read my fair share of


Health Law Alert: New Resources for a Compliance Program Tune-Up
  • Ulmer & Berne LLP
  • USA
  • April 4 2017

It is more important than ever to have an effective internal corporate compliance program tailored to your organization’s compliance risks. Funding


When FINRA Can’t Discipline The Firm, Individuals Pay The Price
  • Ulmer & Berne LLP
  • USA
  • March 30 2017

There has been a lot of discussion over the past few years, including in this blog, about the growing - and troubling - trend for Chief Compliance


SEC Gives Advisors A Break On Custody Rule
  • Ulmer & Berne LLP
  • USA
  • March 23 2017

A common complaint that I hear from broker-dealers and investment advisors is that it is nearly impossible anymore to obtain informal guidance from


FINRA’s New Rules On Seniors: Let’s Protect Them From Their Own Bad Decisions?
  • Ulmer & Berne LLP
  • USA
  • March 22 2017

We have written before about senior investors, but I saw a couple of things in the last couple of weeks that suggests this subject needs to be


Beware the 10-K Ruse: Hackers Target SEC Reporting Companies
  • Ulmer & Berne LLP
  • USA
  • March 15 2017

Employees of Securities and Exchange Commission (SEC) reporting companies are the targets of a new cyberattack. On March 8, the SEC issued a notice


DOL Seeks To Clarify Fiduciary Rule Timing With Temporary Enforcement Policy
  • Ulmer & Berne LLP
  • USA
  • March 14 2017

On Friday evening, March 10, 2017, the Department of Labor (DOL) issued a field assistance bulletin establishing a new temporary Enforcement Policy