Substantive judgment in a narrow set of niches.

SEC Enforcement Defense

Subpoena response, Wells notices, on-the-record interviews, settlement negotiation, and defense for individuals and entities under SEC or CFTC (Commodities Futures Trading Commission) investigation.

Whistleblower Representation

Form TCR filings, Dodd-Frank protections, anonymous submissions, and SEC and CFTC whistleblower award applications, informed by years inside the SEC's Office of the Whistleblower.

Securities Compliance

Compliance program design, examination preparation, and regulatory risk assessment for registered investment advisers, broker-dealers, and fund managers.

Internal Investigations

Independent counsel to boards and audit committees on whistleblower reports, accounting irregularities, and potential FCPA exposure, including scoping, witness interviews, factual findings, and advice on remediation and self-reporting, informed by the regulator-side perspective these reviews require.

Broker-Dealer & Investment Adviser

FINRA, NYSE, and NASDAQ enforcement defense and disciplinary proceedings. Compliance counseling (including creating and improving policies) for RIAs, broker-dealers, and fund complexes.

Comment Letters

Substantive comment letters to the SEC, FINRA, NYSE, and NASDAQ on proposed rulemakings.

Capital Raising & PPMs

Representation in FINRA Arbitrations

FINRA Dispute Resolution is a principal forum for securities-industry disputes, both between customers and member firms and among firms and their associated persons.

Securities Fraud Defense

Defense of insider trading, market manipulation, and accounting fraud matters, including those that proceed on parallel tracks before the SEC, CFTC, DOJ, and the SROs.

Referral & Local Counsel

Co-counsel and local-counsel arrangements for firms facing conflicts, capacity constraints, or a gap in securities depth.