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Ulmer & Berne LLP | USA | 11 Dec 2018

The Real Lesson From FINRA’s 2018 Exam Findings Report

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

Ulmer & Berne LLP | USA | 7 Nov 2018

Ohio Supreme Court Clarifies the Definition of “Participating in or Aiding” Securities Fraud

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…

Ulmer & Berne LLP | USA | 5 Nov 2018

Money Talks, And FINRA Is Listening

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…

Ulmer & Berne LLP | USA | 30 Oct 2018

All’s Fair When It Comes To Arbitrator Ranking

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

Ulmer & Berne LLP | USA | 3 Oct 2018

Department of Homeland Security Announces Proposed Rule Redefining the Term “Public Charge”

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

Ulmer & Berne LLP | USA | 1 Oct 2018

Tips For Staying Off The SEC’s Naughty List In 2019

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…

Ulmer & Berne LLP | USA | 24 Sep 2018

FINRA Plays Guessing Game With Expungement Waiver Request

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

Ulmer & Berne LLP | USA | 31 Aug 2018

Temporary Suspension of Premium Processing for Cap-Subject H-1B Extended

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

Ulmer & Berne LLP | USA | 16 Aug 2018

Ameriprise Learns The Hard Lesson That To Be Deemed “Reasonable,” A Supervisory System Actually Has To Work

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…

Ulmer & Berne LLP | USA | 13 Aug 2018

SEC Civil Penalty Against Charles Schwab Reflects New Trend in Enforcement of SAR Requirements

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