Perspectives

Catch Part 1 here.

If 2024 was the year of emerging compliance trends, 2025 is the year of enforcement-level specificity. Employers are facing new laws that regulate everything from how to write a job posting to how quickly you must deliver a personnel file. Below, we go beyond the headlines and into the weeds on state laws that will affect your team’s procedures, documentation, and legal exposure.

Sick Leave Laws are No Longer Optional-They’re Complex

Forget the “one-size-fits-all” paid sick leave policies. States are now layering in nuanced rules that make multi-jurisdicitonal compliance a challenge.

Minnesota (ESST Updates)

• Effective July 1, 2025, the standarad for notice changed from “as soon as practicable” to “as reasonably required by the employer.”
• Employers may now require reasonable documenation after just 2 consecutive missed days (down from 3).
• Clarified that employees may voluntarily trade shifts to cover ESST balances.

Michigan (Earned Sick Time) 

• Accrual: 1 hour per 30 hours worked.
• Caps:
  • Small employers (fewer than 10 employees): 40 hours/year
  • Larger employers: 72 hours/year
• Carryover allowed, but capped by employer size.
• Effective: February 21, 2025 (most employers); October 1, 2025 (small employers)

Nebraska (Amended June 2025)

• Applies to employers with 11+ employees and those working 80+ hours/year in NE.
• Accrual: 1 hour per 30 hours worked
• Caps: 40 (for 11-19 employees) or 56 hours  (20+ employees)
• Unlimited carryover is permitted, but employers may limit usage annually.

✅ Compliance Tip: You must track hours worked by location if employees across state lines, especially in remote or hybrid work arrangements.

Pay Transparency Laws are Rewriting Job Postings

Employers in multiple states must now treat job postings as legal documents-with specific, required disclosures.

Illinois

• Must list wage/salary range and benefits in job postings (15+ employees)
• Must notify employees of internal promotion opportunities within 14 days of an external posting.

Massachusetts

• Starting February 1, 2025, employers with 100+ employees must report race, gender, and pay data under wage reporting rules.
• October 29, 2025: Employers with 25+ employees must disclose:
  • Pay range in job postings
  • Pay range upon request

New Jersey (June 2025)

• Applies to employers with 10+ employees
• Job postings must include:
  • Wage or wage range
  • List of all benefits and compensation programs available within the first 12 months.

✅ Audit Action: Do your job posting templates meet the strictest state requirements? If not, your risk increases every time a position is advertised.

Whistleblower, “Captive Audience”, and Political Neutrality Protections are Expanding

Sates are implementing laws that prohibit employers from influencing employee political or religious views.

California

Employers may not require attendance at meetings promoting religious or political views.

New laws require posting of whistleblower rights-model notice available from the state.

Rhode Island

Effective July 2, 2025: Employers may not retaliate against employees who refuse to attend meetings focused on employer opinions related to religion or politics.

Illinois

Employers may not:

• Discriminate against employees for their reproductive health decisions.
• Discriminate based on family responsibilities, including caring for ill family members.
• Retaliate against employees for disclosing saftey or legal concerns in good faith.

✅ Training Update: Managers need to be trained to avoid language or behavior that could trigger claims under these new categories of protected rights.

Personnel Records Access, Posters, and Pay Stub Disclosures

States are adding detailed administrative and notice requirements that can result in penalties if missed.

Washington

• Personnel file access: Employers must provide copies within 21 days upon request-free of charge.
• Definition of personnel file incudes:
  • Job applications
  • Performance Reviews
  • Disciplinary records (even if closed)
  • Reasonable accommodation records
  • Payroll and employment agreements

Ohio

Pay Stub Protection Act (April 8, 2025): Must include net/gross pay, hours worked, deductions, and more in written or electronic statements.

Pennsylvania

Employers with 50+ employees must physically or electronically post a new veteran’s rights notice by January 1, 2026.

✅ Poster & Recordkeeping Audit: Make sure posters are updated by state and confirm your HRIS system can fulfill document requests quickly.

AI Regulations and Automated Hiring Tools

Employers are being held responsible for discriminatory outcomes even if they use third-party AI tools.

California

Final employment regulations prohibit use of automated decision systems that result in protected class discriminationincludes tone of voice, facial recognition, or other biometric tools.

New Jersey

Clarifies that liability exists even if the employer did not build the AI tool. The key factor is how the AI was used and whether it created disparate impact.

Texas

Texas Responsible Artificial Governance Act (January 1, 2026): Explicit ban on intentional AI-driven discrimination. 

✅ Policy Alert: Companies must create an AI usage policy, train HR teams, and review third-party vendor tools.

Wrapping It Up: It’s Time to Shift from Reactive to Proactive Compliance

The pattern is clear: states are stepping into legislate where federal law is silent, often with specific deadlines, disclosures, and technicalities that trip up even well-meaning employers.

Your best protection in this landscape?

• Audit your policies.
• Update your employee handbooks.
• Track state-specific implementation dates.
• Train managers, HR, and compliance teams regularly.
• Partner with legal counsel who can interpret and implement these changes for your unique workforce.

Need Help Untangling This Web?

Our legal and compliance teams are ready to help you:

• Conduct a multi-state compliance audit
• Draft new policies to reflect paid leave and posting requirements
• Review AI and hiring practices for bias and exposure

Reach out to us for a consultation today!

A new Minnesota law introduces significant changes to the state’s worker’s compensation system. Signed into law in May 2024, the bill enacts recommendations from the Worker’s Compensation Advisory Council and is set to impact employers and contractors across industries, especially construction companies and projects involving multiple subcontractors.

Key Updates You Should Know

Protected Claim Amount Increases from $1,000 to $3,000

One of the most notable changes is the increase in the protected claim amount-the portion of a claim shielded from subrogation or third-party recovery-to $3,000 (up from $1,000). This adjustment recognizes inflation and rising medical costs, ensuring injured workers retain a greater portion of their benefits.

Chanages Specific to the Construction Industry

The law also implements targeted updates affecting construction projects:

• Clarifies Liability in Multi-Contractor Projects: When multiple contractors or subcontractors are on-site, liability for worker injuries must be clearly understood. The new law aims to streamline how responsibility is determined in these shared jobsite scenarios.
• General Contractors Take Note: If you work with multiple subcontractors, this law reinforces the importance of maintaining up-to-date worker’s compensation certificates from all parties. It also reitereates the need for strong indeminity language and contractual risk transfer protections.
• Special Employer Rule Adjustments: The statute refines how “special employers” (like staffing agencies or general contractors using temp labor) are treated under worker’s compensation, potentially shifting liability in some claims.

Other Key Provisions

• Clarifies Timelines for Filing and Appeals: The law updates certain administrative timelines to improve efficiency and reduce disputes.
• Improves Transparency in Dispute Resolution: Employers and insurers may see improved predictability in how the Department of Labor and Industry (DLI) and the Office of Administrative Hearings (OAH) process claims.

What This Means for Construction Businesses

If you’re a construction company owner, general contractor, or a business managing multiple subs, now is the time to:

• Review your contracts to ensure proper worker’s compensation coverage and indeminifaction clauses are in place.
• Confirm that you are tracking active coverage for all subcontractors.
• Work with legal counsel to review whether your agreements adequately address risk transfer, especially in light of the protected claim amount increase.

Even if you’re not in construction, any Minnesota employer may see greater benefit amounts retained by workers and adjusted handling of disputed claims.

Need Help Reviewing Your Contracts or Coverage Strategy?

At WFJ, our team can help ensure you’re protected and compliant under Minnesota’s evolving worker’s compensation laws. Reach out to us to discuss how this law could impact your job sites and subcontractor relationships.

Landlords across the Upper Midwest share similar frustrations: late payments, damaged units, drawn-out evictions, and tenants who push lease limits. But how you can respond-and protect your investment-depends heavily on state-specific landlord/tenant laws. In this post, we explore the five most common tenant-related challenges landlords face, plus legal insight for property owners in Minnesota, Wisconsin, North Dakota, South Dakota, and Montana.

Nonpayment or Chronic Late Payment of Rent

Tenants falling behind on rent is the most common and financially damaging issue for landords. Delayed payments can disrupt cash flow, affect mortgage payments, and cause tension in the landlord-tenant relationship.

Tip from WFJ: 

• Use clear lease language: outlining rent due dates, late fees (within legal limits), and consequences for nonpayment.
• Document all communications and payment histories.
• Follow your state’s required notice process before initiating eviction. For example:
  • MN: No statutory notice required for nonpayment before filing, but proper notice may still be best practice.
  • WI: 5-day or 14-day notice depending on lease history.
  • ND, SD, MT: 3-day notices required before court filing.
• Work with legal counsel to ensure proper service of notices and to prepare for court procedings.

Improper Handling of Security Deposits

Security deposit disputes are a leading cause of small claims cases against landlords. Issues often arise from improper deductions, delayed returns, or lack of documentation.

Tip from WFJ:

• Know your state’s timeline for returning deposits:
  • MN: 21 days
  • WI: 21 days
  • ND: 30 days
  • SD: 2 weeks (up to 45 days with written explanation)
  • MT: 10 days (no deductions) or 30 days (with deductions)
• Provide an itemized list of damages and costs.
• Take photos before and after move-in/out to document the unit’s condition.
• Keep records of all repair expenses or cleaning costs deducted from the deposit.

Eviction Process Complexities and Delays

Evictions can be time-consuming, expensive, and emotionally taxing. Missteps in the process (wrong notice form, improper service, or missed deadlines) can result in cases being dismissed.

Tip from WFJ:

• Use state-specific notice forms and timelines-they vary widely.
• Document every lease violation, communication, and attempted resolution
• Avoid “self-help” evictions (changing locks, removing belongings) which are illegal in all five states.
• Engage legal counsel early in the eviction process to ensure proper procedure and avoid costly delays.

Property Damage Beyond Normal Wear and Tear

While minor wear is expected, landlords often face significant damage caused by neglect, misuse, or intentional destruction.

Tip from WFJ:

• Conduct thorough move-in and move-out inspections with signed checklists.
• Include clear lease provisions outlining tenant responsibility for damage.
• In cases of excessive damage, deduct repair costs from the deposit with documentation-or pursue a civil judgment if damage exceeds the deposit.
• Some states allow landlords to include provisions requiring tenants to carry renter’s insurance.

Inconsistent Lease Enforcement or Poor Lease Drafting

Weak, outdated, or vague lease agreements often lead to disputes that favor the tenant. Landlords who don’t consistently enforce terms also risk discrimination or retaliation claims.

Tip from WFJ:

• Use state-specific lease templates that include legally compliant language.
• Ensure the lease covers key issues: rent due date, late fees, entry rights, maintenance, pet rules, occupancy limits, etc.
• Apply rules consistently to avoid claims of selective enforcement.
• Have your lease reviewed by an attorney familiar with the landlord-tenant laws in your state.

Key State-Specific Laws that Impact Landlords

Minnesota

• Eviction filings: Must follow strict notice procedures; unlawful detainer process required.
• Security deposits: Must be returned within 3 weeks of move-out.
• Notice to Terminate Tenancy:
  • Periodic Lease: 1 full rental period’s notice (usually a month).
• Emergency repairs: Tenants may file rent escrow if landlords fail to maintain habitability.
• Retaliation protection: Landlords cannot retaliate against tenants who report violations or request repairs.
• Late fees: Must be disclosed in wiring and cannot exceed 8% of the overdue amount.

Failure to strictly follow the law can lead to dismissal of eviction actions or fines.

Wisconsin

• Eviction process: Must issue a 5-day or 14-day notice dpeending on lease terms and violation.
• Security deposits: Return within 21 days of tenancy termination.
• Entry requirements: At leas 12 hours’ notice before entering a unit.
• Disclosure laws: Must disclose building code violations or flooding risk.
• Abandoned property: No requirements to store a tenant’s abandoned property unless stated in the lease.

Procedural missteps during eviction or deposit returns are a common legal pitfall.

North Dakota

• Security deposits: Return within 30 days; can charge up to 1 month’s rent, or 2 months if tenant has a felony.
• Termination notice: 30 days for month-to-month; no notice required for nonrenewal of a fixed-term lease.
• Eviction: Summary process but must be filed in district court.
• Entry: Reasonable notice required; except for emergencies.

Eviction hearings may be quick, but failing to provide proper documentation or notice can delay possession.

South Dakota

• Security deposits: Must be returned within 2 weeks, or 45 days with itemized statement of damages.
• Termination for Month-to-Month: Requires 30 days’ written notice.
• Eviction: Requires 3-day notice to quit for nonpaymen, then a court filing.
• Entry notice: Must provide reasonable notice; typically 24 hours.

Short notice periods for eviction require landlords to act quickly and accurately.

Montana

• Security deposits: Return within 10 days if no deductions, or 30 days with an itemized list of damages.
• Notice to terminate: Month-to-month-30 days.
• Eviction process: Begins with a 3-day notice, followed by court action.
• Right of entry: Must give 24-hour notice

Montana’s detailed rules on habitability and repair can lead to disputes if landlords don’t keep up with maintenance.

Landlords can minimize risk and avoid costly disputes by proactively reviewing leases, maintaining documentation, and working with legal counsel who understands the specific laws of their state. Investing in legal guidance upfront saves time, money, and stress in the long run. 

Estate planning is one of those tasks that most people know they should do-but often put off. Whether it’s discomfort around discussing mortality, uncertainty about where to start, or the belief that “I don’t have enough to worry about,” many individuals delay putting proper legal documents in place. Unfortunately, that delay can come at a high cost-for you and your loved ones.

In this post, we break down 10 of the most common objections people raise when thinking about estate planning, and offer practical, legal guidance to help you move past them. From creating a simple will to establishing a power of attorney and healthcare directive, the goal is the same: protect your voice, your assets, and the people you care about.

Let’s walk through the top concerns and why now is always the right time to get your documents in order.

“I don’t have enough assets to need an estate plan.”

Legal perspective: Estate planning isn’t just for the wealthy-it’s for everyone. A Last Will and Testament ensures that what you do have goes to the right people, and Healthcare Directives and Powers of Attorney protect you and your loved ones if you’re ever unable to make decisions yourself. Estate planning is ultimately about control and protection, not wealth.

“I don’t know where to start-it feels overwhelming.”

Legal perspective: Estate planning can feel complex, but with the right legal support, it becomes manageable. Start with the foundational documents:

• Healthcare Directive
• Power of Attorney
• Last Will and Testament

An experienced attorney can guide you step by step, making the process easier and ensuring your documents reflect your wishes.

“It’s uncomfortable to think about death or incapacity.”

Legal perspective: Avoiding the conversation doesn’t prevent life from happening-it just increases the burden on your loved ones if something goes wrong. Estate planning gives you peace of mind and is one of the most compassionate things you can do for your family, saving them from uncertainty and costly legal hurdles.

“I’m young and healthy-I can do this later.”

Legal perspective: Accidents and unexpected medical events can happen at any age. Having a Healthcare Directive and Power of Attorney ensures that someone you trust can speak for you if you can’t. Putting a plan in place now means you stay in control, no matter what life brings.

“It’s too expensive to hire a lawyer.”

Legal perspective: Estate planning is often much more affordable than people think, especially compared to the potential cost of probate court or family disputes without proper documents. Investing in these documents now can save your family thousands of dollars-and emotional stress-later.

“I’m not sure who to name as my decision-makers.”

Legal perspective: You don’t need to have the perfect answer right away. Attorneys can help you think through your options and even set up contingencies if your first choice isn’t available. The most important step is to get your initial plan in place-you can always update it as life changes.

“My family knows what I want-I don’t need formal documents.”

Legal perspective: Verbal instructions or assumptions aren’t legally binding. Without written documents, your family may face court delays, disputes, and unwanted outcomes. A Last Will, Healthcare Directive, and Power of Attorney make your wishes clear and enforceable.

“I’ve done my will, so I’m all set.”

Legal perspective: A will is just one piece. You also need a Power of Attorney for financial decisions and a Healthcare Directive for medical choices if you become incapacitated. These documents work together to provide full protection-estate planning isn’t complete without them.

“I don’t want to burden anyone with responsibilities.”

Legal Perspective: Choosing trusted people to act on your behalf is not a burden-it’s a gift of clarity. Without clear direction, your loved ones may face far greater burdens, including court-appointed strangers making decisions for you.

“I can just use online templates to save time and money.”

Legal perspective: DIY estate planning may seem simple, but small errors can make your documents invaid or unenforceable. Laws vary by state, and what seems like a quick solution can lead to expensive legal battles or unintended outcomes. Working with an attorney ensures your documents are legally sound and tailored to your situation.

The pace of employment law updates across the U.S. is accelerating-and for employers, the risk of falling out of compliance has never been higher. As of mid-2025, sweeping federal changes and hundreds of new or amended state laws are reshaping workplace obligations. From salary thresholds to paid leave expansions and non-compete bans, there’s a lot to track.

Here’s a look at several major updates employers should act on now:

The “One Big Beautiful Bill”: Tax Breaks for Hourly Workers

Starting retroactively in 2025, qualifying tipped and hourly workers can deduct certain earnings:

• Tip deductions: Up to $25,000 annually in “qualified tips” (voluntary, non-negotiable, and paid by the customer).
• Overtime deductions: Up to $12,500 in federally mandated overtime wages beyond a standard 40-hour week.

Why it matters: Employers could see tax refunds for 2025. Employers should communicate these changes and prepare for increased payroll-related questions.

The DOL’s New Salary Thresholds for Exempt Employees

If you classify employees as exempt from overtime, pay attention:

• July 1, 2025: Minimum salary= $844/week or $43,888/year.
• January 1, 2026: Minimum salary jumps to $1,128/week or $58,656/year

Why it matters: Misclassification can lead to lawsuits. Now is the time to audit exempt employees and adjust compensation or reclassify roles if needed.

AI and Discrimination Laws

States like California and New Jersey have passed laws banning discriminatory use of AI tools in hiring and HR decisions.

• AI systems that analyze facial expressions or speech may violate anti-bias laws.
• Employers are liable even if they didn’t create the AI tool.

Action tip: If you use automated hiring or decision-making systems, review them immediately for bias.

Paid Leave Expansion Across the U.S.

States like Minnesota, Colorado, Maine, and Delaware are rolling out generous paid leave programs:

• Minnesota’s Paid Family and Medical Leave starts January 1, 2026, offering up to 20 weeks of combined leave.
• Colorado will provide an extra 12 weeks for NICU-related parental leave.
• Delaware’s leave benefits begin in 2026 with up to 80% wage replacement.

What to do: Budget for these changes and update your policies and payroll systems to stay compliant.

Non-Compete Agreements Under Attack

More states are banning or restricting non-competes, especially for healthcare workers:

Arkansas, Indiana, Maryland, Pennsylvania, Montana, Texas and others are banning non-competes for physicians and licensed medical professionals.

Colorado now prohibits certain non-competes for healthcare providers and even restricts what they can communicate to patients post-employment.

Recommendation: Review all non-compete templates and consult legal counsel before issuing new ones.

Stay tuned for Part 2

In Part 2, we’ll look deeper at state-specific sick leave mandates, wage transparency laws, new worker protections (like for whistleblowers and nursing parents), and how employers can stay ahead of these fast-paced developments.

What Every Business Owner Should Know Before Signing

When purchasing or expanding a small business, real estate is often part of the equation-whether it’s a storefront, office, warehouse, or commercial lot. But while real estate can be a valuable asset, the contracts involved can carry major legal and financial risks if not handled properly.

At WFJ, we frequently help small business clients review real estate purchase agreements, leases, and sale-leasebacks tied to business acquisitions. Here’s what you need to know before entering into one of these deals.

Understand What You’re Really Buying

Not all real estate tied to a business is owned by the seller- it could be leased, encumbered, or shared with another entity. Before signing a contract:

• confirm who owns the property
• determine if the business use is allowed under zoning laws
• verify whether any liens, easements, or encroachments exist

Tip: Always request a copy of the title committment and survey during due dilligence.

Review Contingencies Carefully

Purchase agreements should inclue key contingencies to protect your interests, such as:

• Financing Contingency-Gives you the right to cancel if funding falls through
• Inspection Contingency-Lets you walk away if the building has structural or environmental issues
• Zoning/Use Contingency- ensures you can operate the business at that location

Without these clauses, you could be legally bound to complete a bad deal.

Pay Clost Attention to Lease Assignments

If you’re acquiring a business that leases its space, the landlord must usually approve the lease transfer or assignment to you. If the lease doesn’t permit assignments-or if the landlord won’t approve it-you could lose the space entirely.

Best Practice: Have an attorney review the ease terms before the sale and assist with any landlord negotiations.

Be Cautious of Seller Financing and Sale-Leasebacks

Some sellers offer to “carry the paper” (finance the property) or sell the property but lease it back as a tenant. While these can be viable options, they carry risk:

• What happens if the seller stops paying rent or defaults?
• Are the lease terms fair and market-based?
• Is the financing agreement properly secured?

A poorly structured deal could result in unexpected litigation-or leave you holding a property without reliable income.

Protect Yourself with Legal Review

Even the most straightforward real estate deals can involve complex legal language, hidden liabilities, or obligations that follow the property after closing.

Working with an experienced attorney-especially one who understands small business transactions-ensures that:

• the agreement is legally sound
• your liability is limited
• your rights are protected if the deal doesn’t go as planned

The Bottom Line

Real estate can be one of the most valuable assets in a business acquisition-or one of the riskiest. By understanding the key issues and involving legal counsel early in the process, you can move forward with confidence and avoid costly mistakes.

On July 4th, 2025, President Donald Trump signed the One Big Beautiful Bill-a sweeping federal tax package that includes two headline-grabbing provisions: a new deduction for qualified tips and another for qualified overtime pay.

While these deductions are marketed as middle-class tax relief, they bring significant payroll and compliance changes for employers. Here’s what your business needs to know now-and how to prepare for what’s next.

Tip Deduction: Up to $25,000 for Eligible Employees

Employees in jobs that customarily and regularly receive tips-think hospitality or food service-can now deduct up to $25,000 in qualified tips from their taxable income.

To qualify:

• The tip must be voluntary, non-negotiable, and determined by the customer. 
• It must be received in 2025 or later while the provision is in effect (2025–2028).
• The deduction is reduced for high earners: $100 less for every $1,000 earned over $150,000 ($300,000 if filing jointly).

However, not all tip-based professions qualify. Employees in fields such as law, medicine, finance, performing arts, and consulting are excluded from this deduction. * (see the end of the post for a more comprehensive list of included fields.)

What this means for employers:

• You must report both the amount of cash tips received and the employee’s qualifying occupation on their W-2.
• FICA withholding and employer obligations for tips still apply.
• The deduction applies retroactively, so 2025 tips are already in scope.

Overtime Deduction: Up to $12,500 Per Employee

Non-exempt employees under the FLSA who work more than 40 hours per week can now deduct up to $12,500 in qualified overtime pay from their taxable income ($25,000 on a joint return). As with tips, the deduction phases out at higher income levels.

“Qualified overtime” must exceed the employee’s regular rate and be mandated under federal law. It cannot be counted as a qualified tip.

Employer impact:

• You must separately report total qualified overtime on W-2s and possibly Form 1099.
• Updated IRS withholding tables will take affect starting 2026.
• Like the tip deduction, this rule is retroactive for 2025 pay.

Key Takeaways for Employers

These new deductions may increase employee interest in reporting overtime and tips-but that accuracy comes with added responsibility for your business.

Here’s what you’ll need to watch:

• Payroll reporting updates: new W-2 data fields will require software and process updates.
• Recordkeeping requirements: Detailed tracking of qualifying wages, occupations, and hours worked is essential.
• Expiration timeline: These provisions are set to end after 2028 unless extended, so employers should prepare for both implementation and sunsetting.
• Behavioral shifts: More employees may seek tipped or overtime work, which could ease staffing gaps but also raise overtime costs.
• State taxes: These are federal deductions only-your state tax obligations may not change.

What Comes Next from the Treasury

The law directs U.S. Treasury (via the IRS) to:

• Publish a list of eligible tipped occupations within 90 days.
• Issue regulations to prevent misclassification of wages as tips.
• Provide new withholding guidance starting in 2026.
• Allow employers to use reasonable estimation methods to comply during the 2025 transition period.

How WFJ Can Help

Industries like hospitality, healthcare, retail, construction, and service are likely to feel the biggest impact from these changes. But any business with tipped or non-exempt employees should take note.

The WFJ Compliance Center is monitoring IRS rulemaking closely and can help your business:

• Interpret the new federal requirements
• Adjust internal systems and payroll process
• Maintain compliance and avoid reporting errors

If your team is affected by these new provisions, now is the time to act. Contact us today to get ahead of these changes and ensure your reporting compliance practices are ready for what’s next.

*Additional fields excluded from tip deductions

• health
• law
• engineering
• architecture
• accounting
• actuarial science
• performing arts
• consulting
• athletics
• financial services
• any trade or business where the principal asset of such trade or business is the reputation or skill of 1 or more of its employees
• investing
• investing management
• trading
• dealing in securities partnership interests
• commodities