Fran Goins

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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 year, but was delayed consistent with President Trump’s order to the DOL to further review the Rule’s impact on the…
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 virus, as it relates to the financial services world. – Alan We are now one week into the worldwide cyberattack…
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 comment by the DOL on March 2, 2017 in response to a Presidential Memorandum to the Secretary of Labor, dated February…
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 otherwise.  – Alan On February 3, 2017, President Trump signed a memorandum addressed to the Secretary of Labor directing that the…