Compliance programs for RIAs, broker-dealers, fund managers, and other registrants, from initial design through exam readiness and risk assessment. Programs built for the operating business, rather than templates that read well on the page and fail under examination.
Compliance programs for RIAs, broker-dealers, fund managers, and other registrants, from initial design through exam readiness and risk assessment. Programs built for the operating business, rather than templates that read well on the page and fail under examination.
Programs are not standardized
Compliance programs are not standardized. The right program for a five-person registered investment adviser is not the right program for a multi-strategy fund complex or a broker-dealer with retail customers under Regulation Best Interest. Off-the-shelf templates pass an initial review, then fail under examination pressure when the specifics of the business do not match the policies on the page.
The firm builds and revises compliance programs around the actual business: the products and strategies, the customer or investor base, the trading practices, the conflicts, the marketing posture, the use of placement agents and finders, the custody arrangements, and the operational seams where compliance ownership is unclear.
The deliverable
We develop a compliance program that an examiner can read in an afternoon and understand, and that the firm's staff can actually follow. Length is not the measure. Specificity to the operating business is, alongside clear accountability for each policy and a defensible record of how the policies are tested.
Annual reviews under Rule 206(4)-7 are treated as substantive exercises, not paperwork. The review documentation is the first thing an examiner asks for, and the quality of that documentation signals more about a firm's compliance posture than the policies themselves.
Examination preparation
Examination preparation follows a similar blueprint, at a different stage of the process. The questions on a typical SEC or FINRA examination are public, the document requests are predictable, and the topics of focus rotate. Preparing for an examination means knowing which of those topics fits the business, where the gaps are, and what the firm will say when an examiner asks.
Mock document requests, mock interview preparation for senior staff, and a written examination playbook are standard components. None of this is theater, examiners can tell.
Regulatory risk assessments
Regulatory risk assessments, the operational, conflict, and disclosure questions that drive most enforcement referrals, are usually faster than clients expect. They are also the work most likely to surface issues that can be remediated before they become matters.
The output is a short written assessment with a prioritized remediation list, not a 200-page deliverable. Issues are framed in the language the relevant regulator uses, so internal stakeholders and outside counsel work from the same vocabulary.
Whistleblower Programs and Dodd-Frank
There is no single federal whistleblower program. "Whistleblower law" is a collection of separate frameworks administered by different agencies, each with its own eligibility rules, reporting procedures, confidentiality protections, and award structures. Which framework applies shapes a matter from the first step, sometimes before a client realizes a choice is being made.
One label, several programs
The SEC and CFTC whistleblower programs, created under the Dodd-Frank Act, pay awards of 10 to 30 percent of the monetary sanctions the government collects in qualifying actions. They are the programs that draw the most attention, and the largest awards.
Beyond Dodd-Frank, the landscape widens. The IRS program is far older and pays awards in qualifying tax cases. The False Claims Act permits individuals to sue on behalf of the government in certain fraud cases and share in any recovery, an area the courts are actively reshaping. The Department of Justice operates its Corporate Whistleblower Awards Pilot Program, launched in 2024 and since expanded, with the first awards already paid. And FinCEN is building out its anti-money laundering program, with proposed rules published in spring 2026.
These frameworks are not interchangeable. They differ on who is eligible, whether a report can be anonymous, what retaliation protections attach, how awards are calculated, and what the first filing must look like.
The firm's focus: the Dodd-Frank programs
Christina concentrates specifically on the Dodd-Frank side of whistleblower law: the SEC and CFTC programs. She served for years as Senior Counsel in the SEC's Division of Enforcement, in its Office of the Whistleblower, the office that administers the SEC program. She has seen how tips are received, evaluated, and pursued from the regulator's side of the table.
That experience shapes the work: Form TCR submissions drafted so the staff can act on them, anonymous submissions made through counsel under Rule 21F, award applications on Form WB-APP, and counsel on the Dodd-Frank confidentiality and anti-retaliation protections that attach along the way.
Matters that belong under other frameworks, tax, False Claims Act, or otherwise, are referred or co-counseled when a sensible arrangement exists. The firm would rather route a matter correctly than stretch to keep it.
Why the distinction matters early
The first step a would-be whistleblower takes can help a matter or hurt it. Reporting through the wrong channel can compromise eligibility for an award, forfeit anonymity, or leave protections on the table. Sorting out which program applies, and what the first filing should be, is exactly the conversation to have before anything is submitted.