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Article II Appointments Clause Defense To SEC Administrative Actions Gains Momentum In The Courts
  • Ulmer & Berne LLP
  • USA
  • February 20 2017

Here is Part II of Ken Berg’s analysis of constitutional defenses that have been raised in response to the SEC’s increased use of administrative


Tell Me Something I Don’t Know: OCIE’s Tips To Surviving An SEC IA Exam
  • Ulmer & Berne LLP
  • USA
  • February 14 2017

Let’s chalk this one up to “great minds think alike,” or maybe just “minds think alike.” You may recall that in his recent letter to member firms


Is There A Catch-22 To Fighting FINRA Charges?
  • Ulmer & Berne LLP
  • USA
  • February 13 2017

Here is a fascinating analysis by my partner, Michael Gross, of FINRA’s twisted logic when it comes to sanctions: your very decision not to admit


HIPAA Breach Notification Enforcement Action: U.S. announces first settlement of enforcement action for failure to timely report a data breach
  • Ulmer & Berne LLP
  • USA
  • February 8 2017

In early 2017, the U.S. Department of Health and Human Services (HHS) Office of Civil Rights (OCR) announced its first settlement for failure to


FINRA Is Going RogueAgain
  • Ulmer & Berne LLP
  • USA
  • February 8 2017

I read an article this week bemoaning the fact that “rogue brokers” - a term that is commonly used but steadfastly undefined - apparently remain


Call to action!
  • Ulmer & Berne LLP
  • USA
  • February 7 2017

I just thought everyone should know that the Federal Historic tax credits are in clear jeopardy of being repealed as part of the Trump


Trump Actions on the DOL Fiduciary Rule and Dodd-Frank
  • Ulmer & Berne LLP
  • USA
  • February 6 2017

Here are some important observations from my partner, Fran Goins, on two missives President Trump issued on Friday that you should know about. My own


Supervision Requires More Than Trust; It Means Trust With Verification
  • Ulmer & Berne LLP
  • USA
  • February 3 2017

Back in December, the State of Massachusetts filed a Complaint against LPL and one of its big producers alleging that the producer, Roger Zullo


Admissibility of Fire Origin and Cause Opinions - 2016 Year in Review
  • Ulmer & Berne LLP
  • USA
  • February 2 2017

2016 produced a variety of court decisions that emphasized the continuing adoption


Is FINRA Guilty Of Gaslighting Us When Its CEO Says Things Will Be Different?
  • Ulmer & Berne LLP
  • USA
  • January 27 2017

Since the presidential election, heck, since the campaign, my friends and family will readily attest that my new favorite word is "gaslighting."