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OCR Launches Phase 2 of HIPAA Audit Program
  • Ulmer & Berne LLP
  • USA
  • April 13 2016

In March, the Office of Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) announced that Phase 2 of its audit program has


Not So Naked And Not So Afraid: FINRA’s New Compensation Rule Does Not Require Brokers To Bare All (Financially) When Changing Firms
  • Ulmer & Berne LLP
  • USA
  • April 13 2016

Two years ago, FINRA first proposed to the SEC a rule that would require brokers to disclose to clients not only when they receive compensation


FINRA’s Response To Request For Help: Call Someone Who Cares
  • Ulmer & Berne LLP
  • USA
  • March 31 2016

I had an experience with FINRA this week that cannot go without comment, as it highlights one of the biggest issues that my clients and I have with


FINRA’S Ability To Enforce Securities Act Violations Subject To Compelling Court Challenge
  • Ulmer & Berne LLP
  • USA
  • March 30 2016

Last week, word spread about a legal challenge that has been mounted in federal court against FINRA's ability to enforce violations of the Securities


Highlights from Day Two of SIFMA-CL Conference
  • Ulmer & Berne LLP
  • USA
  • March 15 2016

Today’s sessions opened with what was likely the highlight of the entire conference, Rick Ketchum’s swan song “conversation” with Ira Hammerman, GC


Highlights from Day One of SIFMA-CL Conference
  • Ulmer & Berne LLP
  • USA
  • March 14 2016

If you are reading this blog, then you, like me, have been probably eagerly waiting for the start of SIFMA’s annual Compliance and Legal conference


Coming Soon - Watch for New Department of Labor Overtime Exemption Regulations
  • Ulmer & Berne LLP
  • USA
  • March 10 2016

In response to a request from President Obama, the Department of Labor (DOL) published a proposed change to the "white collar" exemptions to the


A Miscellany Of FINRA Issues A Little Too Big To Call Nitpicking
  • Ulmer & Berne LLP
  • USA
  • March 9 2016

For some reason, a bunch of noteworthy events all happened around the same time this week, so please bear with me as I vent a little about them


FINRA Merely Wants To Understand Your Firm’s “Culture” (And I Have A Bridge To Sell You)
  • Ulmer & Berne LLP
  • USA
  • March 4 2016

By now you have probably read FINRA's recent "Targeted Exam Letter" entitled "Establishing, Communicating and Implementing Cultural Values." In case


PIABA Cries Wolf, Again, To Ensure That Its Lawyers Get Paid
  • Ulmer & Berne LLP
  • USA
  • February 26 2016

Once again, I found myself gritting my teeth in frustration after reading yet another PIABA report complaining about some perceived inequity in the