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Results:1-10 of 288

The Real Lesson From FINRA’s 2018 Exam Findings Report
  • Ulmer & Berne LLP
  • USA
  • December 11 2018

On Friday last week, FINRA released a report discussing the findings from its 2018 exams, providing what it described as “selected observations” that


Ohio Supreme Court Clarifies the Definition of “Participating in or Aiding” Securities Fraud
  • Ulmer & Berne LLP
  • USA
  • November 7 2018

In a recent landmark decision, the Ohio Supreme Court declared that R.C. 1707.43 does not impose joint and several liability on a custodian of a


Money Talks, And FINRA Is Listening
  • Ulmer & Berne LLP
  • USA
  • November 5 2018

Last year I wrote about FINRA’s effort to encourage firms to self-report their problems, pausing to wonder at the suggestion attributed to Jessica


All’s Fair When It Comes To Arbitrator Ranking
  • Ulmer & Berne LLP
  • USA
  • October 30 2018

I just read an article about a research study conducted of FINRA arbitrations by three people associated with Harvard, Stanford, and the University of


Department of Homeland Security Announces Proposed Rule Redefining the Term “Public Charge”
  • Ulmer & Berne LLP
  • USA
  • October 3 2018

The Department of Homeland Security (DHS) has posted on its website the text of its much-anticipated proposed rule redefining the term “public charge


Tips For Staying Off The SEC’s Naughty List In 2019
  • Ulmer & Berne LLP
  • USA
  • October 1 2018

I recently had to the opportunity to sit in on a talk from high ranking CFTC and SEC enforcement officials at a local bar association meeting. The


FINRA Plays Guessing Game With Expungement Waiver Request
  • Ulmer & Berne LLP
  • USA
  • September 24 2018

When a registered rep contacts us about seeking expungement of customer complaints from his or her CRD record, we always respond that expungement is


Temporary Suspension of Premium Processing for Cap-Subject H-1B Extended
  • Ulmer & Berne LLP
  • USA
  • August 31 2018

U.S. Citizenship and Immigration Services (USCIS) has announced it will extend its suspension of premium (expedited) processing for certain H-1B


Ameriprise Learns The Hard Lesson That To Be Deemed “Reasonable,” A Supervisory System Actually Has To Work
  • Ulmer & Berne LLP
  • USA
  • August 16 2018

A little over a year ago, I blogged about a FINRA Enforcement action against an Ameriprise rep - but, notably, not Ameriprise - to highlight what a


SEC Civil Penalty Against Charles Schwab Reflects New Trend in Enforcement of SAR Requirements
  • Ulmer & Berne LLP
  • USA
  • August 13 2018

The question of whether it is necessary to file a suspicious activity report (SAR) recently became more complex for members of the financial services