According to the SEC: "Defendant engaged in acts and practices that created and/or maintained inappropriate influence by investment banking over research analysts, thereby creating conflicts of interest for its research analysts. Defendant failed to manage these conflicts in an adequate manner. During this time period, Defendant offered its research analysts and securities research coverage in order to assist in gaining investment banking business and receive investment banking fees. It also received payments from other investment banks to cover their investment banking clients, and made payments to other securities firms primarily for research coverage for its investment banking clients. In addition, Defendant compensated its research analysts based in part upon their contributions to Defendant's investment banking business. These relationships and activities constituted substantial conflicts of interest for Defendant's research analysts."

On March 19, 2010, the SEC published a litigation release announcing that the Honorable William H. Pauley issued an order approving modifications to the final judgments entered against USB Securities LLC and the other firms covered by the Global Research Analyst Settlement.

On December 5, 2025, the SEC stated that: "[It] consented to modifications to the October 2003 . . . and September 2004 . . . final judgments against settling firms still covered by the Global Research Analyst Settlement, a global settlement of SEC and other enforcement actions against twelve investment banks and two individuals. The modifications are subject to court approval."

The SEC stated: "[T]he Securities and Exchange Commission (SEC) consents to the relief sought by the motions and agrees that the final judgments should be modified as reflected in the proposed orders submitted by each respective Defendant. . . . Based on these unique facts and circumstances, the SEC believes modification of the Judgment is in the public interest."