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Results: 1-10 of 161

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


SEC ALJs, Part 3: Separation Of PowerRemoval Defense Rides On Coattails Of Reinvigorated Appointments Clause Defense
  • Ulmer & Berne LLP
  • USA
  • March 2 2017

In my second post on constitutionally-based affirmative defenses to SEC administrative proceedings, I discussed the shift of momentum in favor of the


FINRA OTRs: Preparation Is The Key
  • Ulmer & Berne LLP
  • USA
  • March 1 2017

Last week, I published a post about the benefits of “lawyering up” when dealing with FINRA, particularly to handle the defense of an OTR. Here, my


Latest CFPB Report Reveals Consumers’ Steady Focus on Mortgage Issues
  • Ulmer & Berne LLP
  • USA
  • February 23 2017

Earlier this month, the Consumer Financial Protection Bureau (CFPB) issued its monthly complaint snapshot report, which highlights consumer


Puerto Rico Customer Arbitrations: The Untold Story About Why So Many Settle
  • Ulmer & Berne LLP
  • Puerto Rico, USA
  • February 23 2017

Craig McCann, who testifies regularly (but not exclusively) for claimants in FINRA customer arbitrations, must not be as busy as he would like. A few


It Can Pay To “Lawyer Up” When Dealing With FINRA
  • Ulmer & Berne LLP
  • USA
  • February 22 2017

I realize that the title of this blog post may sound self-serving, so I apologize for that up front, as it is not my intent. Still, there is a lesson


Delaware Again Tightens Standards for M&A Plaintiffs’ Suits
  • Ulmer & Berne LLP
  • USA
  • February 21 2017

The Delaware Supreme Court recently dealt another crushing blow to the Revlon doctrine that had governed review of mergers and sales of companies for