Yesterday, two of my colleagues here at Ulmer, Fran Goins and Michael Hoenig, published an article in @BLaw Insight in response to a recent report by FINRA outlining the best practices for BDs to deal with cyber threats. Since this is undoubtedly a subject of considerable interest to many of you, I wanted to share
Goins
OMB Approves Additional Delay For Further Study Of The DOL Fiduciary Rule
The Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) announced this week that it was effectively approving a delay in full implementation of the Department of Labor (DOL) Fiduciary Rule. After several years of study and comment, the final version of the Rule was originally slated to take effect earlier this…
WannaCry Virus Triggers SEC Security Alert To BDs And Investment Management Firms
Readers of this blog know that sales practice issues represent my sweet-spot. Today, in what is probably a welcome departure from my rants, my partner (and co-chair of Ulmer’s Financial Services & Securities Litigation Group) Fran Goins, who knows all things about data privacy and cybersecurity, offers some helpful advice on dealing with the WannaCry…
DOL Seeks To Clarify Fiduciary Rule Timing With Temporary Enforcement Policy
On Friday evening, March 10, 2017, the Department of Labor (DOL) issued a field assistance bulletin establishing a new temporary enforcement policy for the DOL Fiduciary Rule set to become effective on April 10, 2017. (See here) The temporary policy was designed to deal with industry uncertainty created by a new rule proposed for …
Trump Actions on the DOL Fiduciary Rule and Dodd-Frank
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 politics have made themselves pretty clear in recent posts, so it’s good to have someone comment on these presidential pronouncements without the snarkiness I would have undoubtedly injected, wittingly or …