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.

The Court stated: "The modifications are subject to court approval." The Commission stated: "In its responses to the motions, the SEC acknowledges the sunset provision in Addendum A of the final judgments and the passage of FINRA Rule 2241, states that it 'believes modification of the Judgment is in the public interest,' and consents to the requested modification of the final judgments."

The Court stated: "Defendants filed an unopposed motion pursuant to Rule 60(b) of the Federal Rules of Civil Procedure to modify final judgments in the above-captioned cases." The Commission stated: "Based on these unique facts and circumstances, the SEC believes modification of the Judgment is in the public interest."