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Minneapolis, MN 55402, United States

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OIG Outlines Major CFPB Management Challenges

The Office of Inspector General, or OIG, of the Board of Governors of the Federal Reserve System has issued its first listing of major management challenges facing the CFPB. These challenges represent what OIG believes to be the…more
| Administrative Law, Consumer Protection, Finance & Banking

Providing Audited Financial Statements Late Leads to Charges of Custody Rule Violations

The SEC announced charges against an investment advisory firm and three of its top officials for violating the “custody rule” that requires firms to follow certain procedures when they control or have access to client money or…more
| Commercial Law & Contracts, Finance & Banking, Securities Law

DOL Issues Final Rule on Enforcement of Contractors' Minimum Wage Executive Order

On October 1, 2014, the Department of Labor (DOL) issued its "Final Rule" on enforcement of Executive Order No.13658: Minimum Wage for Contractors, which was signed by President Obama on February 12, 2014.The Executive Order…more
| Construction Law, Labor & Employment Law, International Law & Trade, Government Contracting

IRS Announces 2015 Benefit Plan Limits

The Internal Revenue Service has released the 2015 cost of living adjustments affecting dollar limits on benefits and contributions under qualified retirement plans…more
| Labor & Employment Law, Taxation

“Harmonizing” Contract Language Leads Two Circuit Courts To Deny Arbitration

Two parties recently convinced federal circuit courts that the language of their arbitration agreements was not sufficient to compel arbitration of their disputes. Both cases turned on how courts “harmonize” language from…more
| Alternative Dispute Resolution (ADR), Civil Procedure, Commercial Law & Contracts

Regulators Approve Securitization Risk Retention Rule

Six federal agencies approved a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall Street Reform…more
| Commercial Law & Contracts, Finance & Banking, Real Estate - Residential, Securities Law

ISS Proposes New Methodology For Evaluating Equity Plan Proposals

A key component to evaluating whether to place an equity plan proposal in a proxy is whether or not ISS will support the plan. Accoding to ISS, while it has historically recommended against approximately 30 percent of equity…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law

ISS Considering Changing Course on Independent Chair Shareholder Proposals

ISS is requesting feedback on a change to its voting policy on independent chair shareholder proposals. ISS’ current policy is to generally recommend for independent chair shareholder proposals unless the company satisfies all…more
| Commercial Law & Contracts, Securities Law

FINRA Reminds Anti-Whistleblower Provisions Are Not Permitted in Settlement Agreements

FINRA has published a regulatory notice where it reminds firms that it is a violation of FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade) to include confidentiality provisions in settlement agreements or…more
| Alternative Dispute Resolution (ADR), Civil Rights, Labor & Employment Law, Finance & Banking, Securities Law

Second Federal Circuit Court Refuses To Enforce Arbitration By South Dakota Tribe

Using a different analysis, but reaching the same result as a recent decision from the Seventh Circuit, the Eleventh Circuit agreed that a defendant could not compel arbitration of consumer claims before the Cheyenne River Sioux…more
| Alternative Dispute Resolution (ADR), Civil Procedure, Commercial Law & Contracts, Consumer Protection, Indigenous Peoples

Health & Human Services, Office of Inspector General, Proposes New Fraud and Abuse Rules

The U.S. Department of Health & Human Services, Office of Inspector General (OIG) published 79 Fed. Reg. 59717 on October 3, 2014. This proposed rule has the potential to have an impact on a broad array of financial arrangements…more
| Health, Science, Computers, & Technology

CFPB Considering Issuing No-Action Letters

The CFPB has issued a proposed policy where it would issue no-action letters in limited circumstances. The proposed policy is designed for new financial products or services where there may be uncertainty about how they fit in…more
| Finance & Banking, Consumer Protection

Spoofing Back in the News — First Criminal Indictment for Spoofing; CFTC Settlement Lays Out Telltale Signs of Spoofing

Last week the government handed down its first criminal indictment for allegedly engaging in “spoofing” and the Commodity Futures Trading Commission settled with Eric Moncada for spoofing. Spoofing is a form of trading in which…more
| Commercial Law & Contracts, Criminal Law, Finance & Banking, International Law & Trade, Securities Law

Major Banks Agree to Temporarily Stay Swap Termination Under ISDA Protocol

The International Swaps and Derivatives Association, Inc., or ISDA, announced that 18 major global banks, referred to as G-18, have agreed to sign a new ISDA Resolution Stay Protocol. The Protocol was developed in…more
| Commercial Law & Contracts, Finance & Banking, Securities Law

It’s Going to be Harder to Sell Unregistered Securities

The SEC has issued a Risk Alert and FAQs to remind broker-dealers of their obligations when they sell unregistered securities on behalf of clients. This occurs when founders and employees sell their initial stakes in companies…more
| Commercial Law & Contracts, Securities Law
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Areas of Practice
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Other U.S. Locations
  • D.C.
  • Minnesota
  • North Dakota
Number of Attorneys

100+ Attorneys

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