Barbara Stettner
1625 Eye Street, NW
Washington, DC, 20006
Phone: +1-202-383-5283
Fax: +1-202-383-5414
-
Chris Salter
1625 Eye Street, NW
Washington, DC, 20006
Phone: +1-202-383-5371
Fax: +1-202-383-5414
-
William Satchell
1625 Eye Street, NW
Washington, DC, 20006
Phone: +1-202-383-5342
Fax: +1-202-383-5414
LAWYERS
- Related Practices
|
Broker-Dealer Regulation and Compliance
Our Broker-Dealer Regulation and Compliance team covers a broad waterfront of issues facing broker-dealers and other US and global financial institutions engaged in securities transactions within the United States, including foreign and domestic banks, insurance companies, investment advisers and private fund managers. Our clients range from financial institutions specializing in investment banking to market leading clearing firms and prime brokers. We have extensive experience counseling foreign and domestic financial institutions on issues related to their status as brokers and dealers and helping financial institutions to register with the Securities and Exchange Commission (“Commission”) and to become members of Self Regulatory Organizations (“SRO”) such as the Financial Industry Regulatory Authority (“FINRA”). We routinely assist newly registered broker-dealers and well established firms in developing written compliance policies and supervisory procedures and conduct reviews of their supervisory systems. We also assist our clients in responding to examinations, inquiries and industry sweeps, and remediate identified deficiencies.
Key Facts
- We counsel broker-dealers on issues related to compliance with the Commission’s financial responsibility rules, including the Net Capital and Customer Protection Rules, and the books and records and financial reporting rules.
- We advise broker-dealers and financial institutions with respect to political activities, including compliance with federal and state regulations and ethics rules covering pay-to-pay, campaign finance, lobbying, and state contracting.
- We represent prime brokers and financial institutions, such as hedge funds and other private funds, negotiate prime brokerage agreements.
- We assist broker-dealers in obtaining SRO approval for changes in ownership or control, significant changes in operations and business lines, and significant asset sales.
- We counsel broker-dealers on compliance issues associated with developing new products, including developing customized disclosures.
- We counsel broker-dealers with respect to collateral consequences that arise in connection with settling disciplinary actions brought by federal and state regulators and the SROs, including counseling with respect to issues concerning statutory disqualification under federal and state securities laws and regulations and SRO rules.
- We represent broker-dealers before federal and state regulators and the SROs to obtain no-action and interpretative relief.
- We counsel broker-dealers with respect to sales practices regulations including suitability, point-of-sale disclosures, gifts and entertainment practices, and compensation structures for representatives.
- We counsel domestic and foreign broker-dealers, private funds, banks and other financial institutions on distributing securities and offering services in the United States, including compliance with Rule 15a-6.
- We counsel financial institutions on broker-dealer status issues, including foreign and domestic finder issues and the “issuer exemption” available under Rule 3a4-1. We also advise financial institutions, including banks and broker-dealer affiliates, on Gramm-Leach-Bliley Act issues, the broker and dealer “push-out” rules, and Regulation R.
- We conduct mock compliance examinations and other compliance reviews and assist broker-dealers comply with annual review and certification requirements.
|
|