Assisted investment adviser clients with SEC registration and compliance examinations conducted by the SEC. Being present with clients during the actual SEC examinations, including routine, cause and presence exams. Conducted mock-compliance exams. Drafting responses to the SEC book and record requests, including inquires related to an adviser’s performance and marketing presentations. Prepared and reviewed compliance procedures.
Assisted investment adviser clients with SEC regulatory filings, including Form ADV, Form 13F, 13H and Form PF. Filed forms directly with IARD and EDGAR.
Prepared privilege logs and responded to various subpoenas from the SEC. Defended on-the-record depositions from the SEC, including insider-trading matters and unregistered broker-dealer cases.
Assisted broker-dealer clients with FINRA registration and examinations conducted by FINRA. Preparing responses to Rule 8210 requests and defending on-the-record depositions from FINRA personnel, including suitability cases and confirmation disclosure cases. Negotiating Acceptance, Waiver and Consent agreements with FINRA. Defending customer complaints in FINRA arbitrations. Defended terminated registered representatives in enforcement actions filed by FINRA. Review of Form BD, Form U-4 and Form U-5 filings.
Assisted Commodity Pool Operators and Commodity Trading Advisers with CFTC and NFA registration and compliance examination conducted by the NFA. Assisted with prior disciplinary disclosures and completing Form 7-Rs and 8-Rs. Drafted no-action relief letters for certain pool operators. Filed exemption notices for family offices, fund-of-funds and Rule 4.13(a)(3) filings. Prepared and reviewed compliance procedures.
Assisted clients with state regulatory filings, including investment adviser filings, blue-sky filings and Form D updates.
Advised various clients with purchasing a broker-dealer or investment adviser.