Milnor Law PLLC

Common questions

Straight talk and candid answers.

The questions below come up most often in initial conversations. None of this is legal advice for any specific situation.

Enforcement

What is a Wells notice and how should I respond?

A Wells notice is a letter from SEC enforcement staff advising a person that the staff intends to recommend that the Commission authorize an enforcement action. It is not a charge. It is an opportunity to respond — a Wells submission — before the Commission votes on whether to authorize a case.

The submission is the single highest-leverage moment in an SEC investigation. It should be written with a clear theory of why charges are wrong on the facts, the law, or the public interest, and it should be paced to the staff's timeline, not the client's.

Whistleblower

Can I file a Form TCR anonymously?

Yes. Under Rule 21F of the Securities Exchange Act, an individual may submit a Form TCR anonymously, provided the submission is made through counsel and counsel verifies the whistleblower's identity to the Commission at the time any award is claimed.

Anonymity is not absolute. There are circumstances — including award claims and certain enforcement contexts — in which identity may need to be confirmed.

How do whistleblower award programs work?

There isn't one federal program; the SEC, CFTC, IRS, DOJ, FinCEN, and the False Claims Act each have different rules, protections, and awards. The standard is narrow, timelines often run five years or more, and which door you knock on first can help or hurt your matter, so getting advice early matters."
Keep, tweak, or skip?

Capital raising

Do I need a private placement memorandum for a small Regulation D raise?

The legal obligations attached to a private securities offering are determined by the nature of the offering — the type of investor solicited, the exemption relied on, the manner of solicitation — not by the dollar amount raised. Many founders are surprised to learn that a small raise can carry the same disclosure obligations as a much larger one.

Whether a PPM is technically required and whether one should be prepared are separate questions. Both are worth answering deliberately.

Engagement

What does engagement with the firm typically look like?

Initial conversations are brief and confidential, subject to a conflict check. The firm declines engagements that fall outside its core competencies, and refers them out when a sensible referral exists.

Because the firm is solo by design, the attorney on the call is the attorney on the matter. There is no associate layer to which the work will be handed.

What jurisdictions does the firm cover?

Christina Milnor is admitted in Virginia and the District of Columbia. Federal regulatory matters, including SEC and SRO proceedings, are handled nationally as appropriate.

Practice

What does Milnor Law focus on?

Milnor Law is a securities practice at the intersection of financial regulation, workplace realities, and internal reporting. We handle SEC enforcement and regulatory matters, advise on whistleblower and internal reporting concerns, and help companies respond thoughtfully when something doesn't look right.

Who do you represent?

Both sides of the table: individuals weighing whether and how to report concerns, and companies that want to handle internal reports, investigations, and regulatory scrutiny with credibility. We especially enjoy working with organizations that value cooperation and doing it right, not just technical compliance.

What is your background?

Christina Milnor spent more than a decade at the SEC, including reviewing enforcement recommendations, before founding Milnor Law. That experience means clients get a realistic view of how regulators think, how investigations unfold, and what actually moves outcomes.

Do you use AI in your practice?

Yes, carefully. We use agentic AI tools for document review, tracking details across complex matters, and first drafts, with security, supervision, and verification built in. That frees more time for the strategy and judgment clients actually hire a lawyer for.

None of the answers on this page constitutes legal advice for any specific matter. Engagement begins after a written engagement letter is signed and a conflict check is complete.