direction to staff in dealing with Ottman’s accounts. Even Ott-man’s counsel admitted, at oral argument, that the second memorandum concerns Ott-man’s customers and his job performance. Because proving the truth or falsity of the memoranda will require presentation of evidence integrally related to Ottman’s performance as a broker, we conclude the defamation claim arises out of the employment or termination of employment and, as such, falls within the scope of the U-4 registration agreement. Cf Morgan, 729 F.2d at 1168 (declining to compel arbitration of claim not implicating employee’s performance as broker). Ottman argues we should not look at the essence of his claim to determine arbitrability, but should review each statement in the two memoranda to determ 66 N.W.2d 726, 730 (1991) (<HOLDING>); Flanagan v. Prudential-Bache Sec., Inc., 67
holding as arbitrable posttermination defamation claim based on statement that stockbroker was basically a criminal holding as arbitrable posttermination defamation claim based on statement that stockbroker had a drinking problem holding that a defamation claim is a personal injury tort claim holding that a defamation claim based on statements in a written disciplinary notice was preempted holding that online service provider was immune from defamation claim based on inaccurate stock information