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Results: 1-10 of 134

FINRA Releases Its 2017 Exam Priorities: No More “Culture Of Compliance” References, Plus The List Of Usual Suspects
  • Ulmer & Berne LLP
  • USA
  • January 6 2017

In the blog I posted yesterday, I discussed a late Xmas present that the 10th Circuit gave everyone who is subject to the SEC’s jurisdiction. Today


2017 Off To A Bad Start For The SEC As The 10th Circuit Finds SEC ALJs To Be Unconstitutional
  • Ulmer & Berne LLP
  • USA
  • January 5 2017

Many industry authors - including me - have devoted a lot of attention lately to the SEC’s increased use of Administrative Proceedings (rather than


President Obama Signs Prohibition on Form Contract “Non-Disparagement Clauses”
  • Ulmer & Berne LLP
  • USA
  • December 30 2016

On December 14, 2016, President Obama signed the Consumer Review Fairness Act of 2016. This Act voids "non-disparagement clauses" in form contracts


Swing And A Miss: A Rare Form U-4 Loss For FINRA
  • Ulmer & Berne LLP
  • USA
  • December 18 2016

I have blogged multiple times, as recently as a couple of weeks ago, about the slew of Enforcement actions that FINRA has brought for an RR’s failure


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