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Broker/Dealer Regulation and Enforcement 2012


Speaker(s): Abbe R. Tiger, Alan M. Cohen, Carmen J. Lawrence, Charles V. Senatore, Christopher J. Mahon, Colleen P. Mahoney, David Meister, Gerard S. Citera, Gregory Johnson, Henry Klehm III, Ilene B. Marquardt, J. Bradley Bennett, James A. Brigagliano, Joseph P. Borg, Kay L. Lackey, Marc B. Minor, Marc P. Berger, Michael J. Osnato, Jr., Nancy L. Swift, Neal E. Sullivan, Ralph DeSena, Susan L. Merrill, William R. Baker III
Recorded on: Oct. 24, 2012
PLI Program #: 34746

Marc B. Minor was appointed as Chief of the Investor Protection Bureau for the New York State Office of the Attorney General in March 2011. He previously served as Chief of the Bureau of Securities for the New Jersey Attorney General. Mr. Minor earned his Juris Doctorate from Howard University School of Law in Washington, DC, and holds both a BS in Journalism and BA in Criminal Justice from the University of Maryland. His previous positions include Senior Counsel for FINRA (f/k/a NYSE Regulation, Inc.), Enforcement Director for the Philadelphia Stock Exchange, and Assistant Attorney General for the New York Attorney General, as well as commercial litigation experience in private practice.

Mr. Minor currently serves as a member of the North American Securities Administrators Association's (NASAA) Broker Dealer, Federal Legislation, and SRO Liaison Committees, chaired NASAA's 2011 Public Policy Conference in Washington, DC, served as panelist for several of Practicing Legal Institute's Coping with Broker Dealer Regulation and Enforcement programs, American Conference Institute on Emerging Market Risks, the SEC and NASAA on Mutual Fund Market Timing, and FINRA/ NYSE/ AMEX hosted CLE on Insider Trading in Options; and lectured at Howard University School of Law, Seton Hall University School of Law, and Rutgers University Business School.


Ralph DeSena is Director & Senior Counsel at the Royal Bank of Canada, which is currently the eleventh largest bank in the world by market capitalization, with more than 74,000 employees serving 15 million clients globally. Ralph is responsible for managing all U.S. regulatory investigations and civil litigations and arbitrations involving RBC's Capital Markets platform. Ralph also has been the chair of SIFMA's Litigation Advisory Committee since 2010 and a member since 2007.

Prior to joining RBC in May 2005, Ralph was a litigator at Morgan Stanley, where he handled litigation, arbitration and regulatory investigations for the individual investor, institutional securities and investment management divisions. He also was heavily involved in the SEC-mandated "top-to-bottom" review of conflicts and business practices, which achieved a major shift in the firm's regulatory strategy. In private practice prior to going in-house, Ralph was a litigation associate in the New York offices of King & Spalding LLP and Rogers & Wells (now Clifford Chance LLP), where his practice focused on securities and antitrust cases. He began his legal career clerking for the Honorable Stewart Dalzell, a federal district court judge in Philadelphia. Ralph graduated from UCLA School of Law in 1994 and received his Bachelor of Arts degree, summa cum laude, from Boston College in 1991.

Ralph is a regular speaker on broker-dealer regulatory enforcement issues, including at the last several SIFMA annual conferences. He recently co-authored "Trio of Second Circuit Decisions Clarifies FINRA Arbitrability," 44 Securities Regulation & Law Report 374 (Feb. 20, 2012).


David Meister heads Skadden’s Government Enforcement and White Collar Crime Group in New York. Having served twice in federal law enforcement — most recently as Enforcement Director of the U.S. Commodity Futures Trading Commission (CFTC) and previously as an assistant United States attorney in the Southern District of New York — Mr. Meister has more than 25 years of experience litigating enforcement and white collar crime matters from both the prosecution and the defense perspectives. He represents financial institutions and other corporations and their boards, and individuals, in matters involving the full range of federal, state and international criminal and enforcement agencies. He has conducted numer­ous jury trials and has led internal investigations throughout his career.

Mr. Meister rejoined Skadden in 2014 after serving for nearly three years as Director of the CFTC’s Enforcement Division, where he was responsible for the overall direction of the program. Under Mr. Meister’s leadership, the CFTC conducted hundreds of investigations involving physical commodities, futures, swaps and other derivatives, and brought record numbers of enforcement actions with record sanctions. For instance, he led the CFTC’s investigation and prosecution of the first-ever Dodd-Frank Act charges; cases involving worldwide LIBOR and other benchmark manipulation; commodities market fraud and manipulation; supervision failures; unlawful trading practices; misuses of customer funds; deficient accounting and auditing; and Ponzi schemes. He also led key Dodd-Frank rule­makings, such as the prohibition against a wide range of manipulative and deceptive conduct and the whistleblower rule.

As Director, Mr. Meister worked closely with top leadership at the SEC, the DOJ and numer­ous U.S. attorneys’ offices, the Federal Energy Regulatory Commission, and other federal and state agencies and self-regulatory organizations across the country, as well as the U.K. Financial Conduct Authority and financial market regulators in Europe, Asia and Australia. He served as co-chair of the Securities and Commodities Fraud Working Group of the Finan­cial Fraud Enforcement Task Force, which President Obama established in 2009. Mr. Meister also was a key liaison with congressional oversight committees.

Prior to his CFTC appointment, Mr. Meister was a partner at Skadden, where he handled a broad array of high-profile white collar matters involving the securities and derivatives markets, complex accounting, insider trading, disclosures, the Foreign Corrupt Practices Act, tax laws and a variety of other subjects. For instance, he acted for clients in cases concern­ing the financial crisis, auction rate securities, mutual fund market timing, collateralized debt obligations, subprime mortgages and credit default swaps. Mr. Meister has extensive cross-border investigative experience and has counseled clients in the U.K., Europe and Asia concerning the impact of U.S. laws abroad. He also has routinely handled complex private litigation in parallel to white collar matters.

Mr. Meister previously served as an assistant U.S. attorney in the U.S. Attorney’s Office for the Southern District of New York, prosecuting a wide variety of cases as a member of that office’s Securities and Commodities Fraud Task Force and representing the government in numerous trials and appeals.

Education

J.D., Columbia University School of Law, 1987 (Harlan Fiske Stone Scholar)

BChE, University of Delaware, 1984 (cum laude)

Bar Admissions

New York

Publications

“The Territorial Barrier to Commodity Exchange Acts Suits,” The National Law Journal, November 13, 2014

“Rule 180.1: The CFTC Targets Fraud and Manipulation,” New York Law Journal, April 7, 2014


Alan is head of Global Compliance. He serves as a member of the Management Committee, the Firmwide Client and Business Standards Committee, the Firmwide Investment Policy Committee and the Firmwide Reputational Risk Committee. Alan joined Goldman Sachs as a partner in 2004.

Prior to joining the firm, Alan was a partner at O’Melveny & Myers, where he co-headed the White Collar and Regulatory Defense Practice and the New York Litigation Group since 1991. Prior to this, he was an assistant US attorney for nine years for the Southern District of New York, where his last assignment was as the chief of the Securities and Commodities Fraud Task Force.

Alan serves on the Board of Directors of the New York Stem Cell Foundation and the Board of Trustees of Temple University. He is also a member of the Lawyers Committee of the Innocence Project.

Alan earned a BA in 1972 from Temple University, as well as a PhD and a JD, with highest honors, from Rutgers University in 1976 and 1979, respectively.


Abbe R. Tiger currently is the Head of Compliance US for Computershare, Inc. and Chief Compliance Officer for Georgeson Securities Corporation. Abbe joined Computershare in October 2013. She is an attorney who has been admitted to practice law since 1983.  Just prior to joining Computershare, Abbe served as the Chief of the New Jersey Bureau of Securities in the New Jersey Office of Attorney General where she oversaw a staff of professional and clerical staff charged with administering all aspects of the New Jersey securities laws.  In that position, Abbe also sat on the Investment Advisor and Enforcement Committees of the North American Securities Administrators Association (NASAA).

Earlier in her career, she served as an Assistant District Attorney in Brooklyn, NY and a Branch Chief in the Division of Enforcement of the US Securities and Exchange Commission in Washington, DC.  Abbe also spent 14 years in various in-house roles at Merrill Lynch including as the Head of Internal Reviews.  Abbe received her BA and JD degrees from the State University of New York at Buffalo.  Abbe holds Series 7, 24 and 99 securities licenses.


Carmen Lawrence is a partner in King & Spalding’s Special Matters and Government Investigations practice group.

Ms. Lawrence's practice focuses on representing parties in investigations and litigations conducted primarily by the US Securities and Exchange Commission, US Commodity Futures Trading Commission, US Department of Justice, self-regulatory organizations and state securities regulators, conducting internal investigations, providing crisis management advice to public and private companies and counseling public companies and regulated entities (broker-dealers and investment advisers) on their obligations under the federal securities laws.

From 1996 until June 2000, Ms. Lawrence was the Regional Director for the SEC's Northeast Regional Office (covering 14 states and the District of Columbia), where she oversaw all enforcement and regulatory operations in the SEC's largest region.  Some of the SEC's most significant cases were brought by the Northeast Regional Office under Ms. Lawrence's leadership.

Before her appointment as regional director, from 1990 through 1995, Ms. Lawrence served as Senior Associate Regional Director, heading up the Northeast Regional Office's Enforcement Division.  From 1981 to 1989, she served in various staff and senior positions in the Enforcement Division.

Ms. Lawrence received numerous awards during her tenure at the SEC, including the Equal Employment Opportunity Award in 1998; the Presidential Distinguished Executive Award in 1995; the Stanley Sporkin Award in 1993; and the Irving M. Pollack Award, presented to an enforcement lawyer exhibiting leadership, integrity and intellect, in 1990. 

Ms. Lawrence is consistently recognized by Chambers USA: America's Leading Lawyers for Business as a leading individual for Securities Regulation and for Litigation: White-Collar Crime & Government Investigations.  She is consistently recognized by Legal 500 in Litigation: White-Collar Criminal Defense, and is additionally recognized in Financial Services: Litigation.  She is also consistently recognized by Benchmark: Litigation as a New York Litigation Star. She was named to Securities Docket’s inaugural “Enforcement 40” list of top SEC enforcement lawyers in 2013.

Ms. Lawrence has spoken extensively and participates in numerous continuing legal education programs for federal securities law matters.


Chuck Senatore is an executive vice president and head of risk oversight for Devonshire Investors, a unit within FMR LLC, the parent company of Fidelity Investments.  Devonshire Investors focuses on long-term investments in operating companies and real estate, as well as the management of private venture funds.   In his role, Mr. Senatore is accountable for oversight and strategic direction pertaining to the compliance, legal, regulatory and risk related functions for Devonshire’s constituent businesses.  He also serves as Chief Compliance Officer for Impresa Management LLC., a registered investment adviser within the Devonshire unit.

In earlier roles at Fidelity, he led the firm’s global compliance and ethics function for over eleven years, and served as the firm’s head of regulatory coordination and strategy.

Prior to joining Fidelity in May 2003, Mr. Senatore served as Co-Head of Global Compliance at Merrill Lynch, and Head of the firm’s Regulatory Affairs Group. From 1994 to 1997, Mr. Senatore served as Director of the Securities and Exchange Commission’s Southeast Region.

Prior to his service at the Commission, Mr. Senatore practiced law in South Florida, and served as an Assistant U.S. Attorney in the Southern District of Florida, including service as Chief of that office’s Public Corruption Section.

Mr. Senatore is a member of the Standing Advisory Group to the Public Company Accounting Oversight Board.  He is also a member of the American Law Institute, advising on its project on the Principles of the Law, Compliance, Enforcement, and Risk Management for Corporations, Nonprofits, and Other Organizations.  He served previously as Chair of FINRA’s National Adjudicatory Council and Chair of the Board of Directors of the National Society of Compliance Professionals.

Mr. Senatore is also a lecturer in law at the University of Chicago Law School, teaching Compliance and Regulatory Strategy.  Earlier, he was an Adjunct Professor of Securities Regulation at the University of Miami Law School.

Mr. Senatore received a Bachelor of Arts in Economics from Williams College and earned a J.D. from the University of Chicago Law School.


Colleen P. Mahoney, a partner in Skadden's Washington, D.C. office, heads the firm's Securities Enforcement and Compliance practice, and regularly represents financial services firms, corporations, their boards, board committees, officers, directors and employees in Securities and Exchange Commission (SEC) and other law enforcement investigations.

Ms. Mahoney assists management and boards of directors performing internal inves­tigations, often advising clients on preventive and remedial measures before and after securities-related issues arise.

Ms. Mahoney has been the lead attorney representing many of the company boards and individuals embroiled in signature SEC investigations. Her clients have included many well-known U.S. and foreign companies. As is frequently the case with SEC enforcement matters, the biggest victories are the ones that never become public – the government investigations and inquiries that are put to rest before charges are filed or an indictment is issued, or even before a public disclosure of the government interest. Ms. Mahoney has succeeded in bringing a number of matters to a close in those circumstances.

Prior to joining Skadden, Ms. Mahoney spent 15 years in increasingly senior positions with the SEC, serving as acting general counsel of the agency and as deputy director of the division of enforcement. During her tenure at the SEC, Ms. Mahoney helped manage a civil law enforcement program that addressed a wide range of issues, including financial fraud and disclosure, asset management issues, derivatives and insider trading.

Ms. Mahoney frequently lectures on securities regulatory and enforcement issues at seminars and conferences in the United States and abroad.

Ms. Mahoney has been selected for inclusion in Chambers USA: America's Leading Lawyers for Business, The International Who's Who of Corporate Governance Lawyers, Lawdragon 500 Leading Lawyers in America and The Best Lawyers in America. Since 2012, she has been recognized as one of Benchmark Litigation's "Top 250 Women in Litigation" and she also was named to the shortlist of the nation's top women regula­tory lawyers by Chambers USA (2012). Additionally, Ms. Mahoney was included in Washingtonian Magazine's 2013 "Best Lawyers" list.

 


Gregory Johnson is a Managing Director and Associate General Counsel with JPMorgan Chase & Co. Inc. and Head of Compliance for its Global Corporate & Investment Bank.  Prior to joining J.P. Morgan in 1997, he was with CS First Boston focusing on fixed income compliance.  From 1990 to 1994, Mr. Johnson was an enforcement attorney and then branch chief with the U.S. Securities & Exchange Commission’s Northeast Regional Office.  Mr. Johnson holds a B.S. in Economics and Finance from St. John’s University School of Business and a J.D. from St. John’s University School of Law.


Henry Klehm, co-head of the Firm’s Securities Litigation & SEC Enforcement Practice, brings almost 30 years of experience at the U.S. Securities and Exchange Commission as a senior enforcement officer, a senior in-house lawyer at two global financial institutions, and a public company director. In the last ten years, Henry has acted as counsel in major corporate investigations and civil and criminal enforcement actions throughout the world. He counsels boards, corporations, and financial institutions on cross-border internal investigations, crisis management, corporate governance, and effective compliance and ethics programs, as well as legal matters related to internal control, auditing, litigation loss contingencies (ASC 450), and whistleblowers.

Recent representations include public companies, audit and special committees, financial institutions, and senior corporate officers in investigations and litigation involving disclosure, complex financial products, financial reporting, the Foreign Corrupt Practices Act, money laundering, and economic sanctions.

Prior to joining Jones Day, Henry was Deutsche Bank’s global head of compliance and Prudential Financial’s deputy general counsel for regulatory matters. He was with the SEC for ten years, serving as head of enforcement for the northeastern United States for five years, where he investigated, litigated, and supervised more than 500 enforcement actions including insider trading, financial frauds, Ponzi schemes, rogue traders, market manipulations, and investment company and advisor matters.

Since 2006, Henry has served as an independent director of RenaissanceRe Holdings, an NYSE-listed catastrophe reinsurance firm. He is currently chair of the Compensation and Governance Committee and previously chaired the audit committee.

Henry frequently lectures on cross border investigations, financial services, and corporate governance matters.


Ilene Marquardt is Head of Regulatory and Other Investigations for UBS Wealth Management US.  In this role, Ilene supervises the attorneys and other professionals who handle significant Regulatory and Internal Investigations, Early Dispute Resolution and Subpoenas, Levies and Garnishments, and coordinates with the Litigation function for UBS Region Americas. In January 2018, Ilene was appointed to the FINRA National Adjudicatory Council (NAC) for a four-year term, and she is also a member of the Securities Industry & Financial Markets Association (SIFMA) Executive Committee for the Compliance and Legal Division.

Prior to joining the Firm (then PaineWebber) in July 1994, Ilene was a Litigation Associate at Morgan, Lewis & Bockius in New York, where she specialized in securities enforcement litigation.  She graduated from NYU School of Law in 1988 and Northwestern University in 1985. 

Ilene is a frequent speaker on industry panels on such topics as regulatory and internal investigations, securities enforcement matters, e-discovery and in-house legal representation.

 


J. Bradley Bennett, Executive Vice President, is responsible for FINRA’s Department of Enforcement. In this capacity, Mr. Bennett directs investigating and bringing all formal disciplinary actions against firms and associated persons for violations of FINRA rules and federal securities laws.

Mr. Bennett received his undergraduate degree from St. Lawrence University and his J.D. from Georgetown University Law Center.

He started his career at the SEC as a senior attorney in the Division of Enforcement focusing on cases of all facets of securities law, including accounting, broker-dealer regulation, tender offers and insider trading.


Joseph Borg has been Director of the Alabama Securities Commission (ASC) since 1994. Borg was twice past president of the North American Securities Administrators Association (NASAA) and is currently serving his third term as President. He served as a member on the NASAA Board of Directors, as Chair of the International Committee, Chair of Enforcement, Ombudsman and in several other capacities. He is also a member of the Board of Directors of the National White Collar Crime Center (NW3C) and previously served as a member of the Board of Directors of the Investor Protection Trust (IPT). He has also served as a member of the SIPC Modernization Task Force and the FINRA Dispute Resolution Task Force.

Borg recently (June 2018) testified before the U.S. House Financial Services Committee, Capital Markets Subcommittee hearing entitled “Ensuring Effectiveness, Fairness, and Transparency in Securities Law Enforcement.” He has previously testified before various committees of the U.S. Senate and U.S. House of Representatives including testimony on such areas as Microcap Fraud; Criminal Elements in the Financial Markets; Information Sharing among Financial Regulatory Agencies; Risks Posed to Everyday Investors from IPOs in Private Equity and Hedge Funds; Illegal Investment Sales’ Practices Victimizing Senior Citizens; and SIPA and SIPC Modernization.

Borg served as a U.S. delegate to an Intergovernmental Expert Group for the United Nations Commission on International Trade and Law (UNCITRAL).

Borg previously served as in-house corporate counsel to First Alabama Bank (n/k/a Regions Bank, 1979-1984) and has been an adjunct professor of law at Faulkner University Jones School of Law teaching securities law and banking (1982-2002), and has been a Partner in the Montgomery law firm of Capouano, Wampold, Prestwood & Sansone (1984-1994).

He is admitted to practice in Alabama, Florida, New York, U.S. Federal District Courts in Alabama and Florida, the 5th and 11th Circuit Courts of Appeal and the U.S. Supreme Court.


Kay Lackey is a Managing Director/Senior Counsel at Royal Bank of Scotland (Americas).  Kay is the Head of Litigation and Regulatory Investigations for Corporate and Institutional Banking.

Prior to joining RBS, Kay worked at the Securities and Exchange Commission for 14 years.  Kay joined the Commission in 1995 as a staff attorney in the Division of Enforcement in New York and was subsequently promoted.  When she left the Commission, Kay was an Associate Regional Director and Co-Head of Enforcement in the New York Regional Office.  While at the SEC, Kay worked on and supervised numerous enforcement actions involving a variety of areas, including financial fraud, stock options backdating, insider trading, market timing and late trading, ponzi schemes, and market manipulation.

Prior to working at the SEC, Kay was a litigation associate at Mayer Brown.  Kay also clerked for the Honorable Nathaniel M. Gorton of the United States District Court for the District of Massachusetts and the Honorable Juan R. Torruella, of the United States Court of Appeals for the First Circuit.  Kay received her J.D. from Boston University Law School and her B.A. from Williams College.


Marc P. Berger was named Director of the New York Regional Office in December 2017.  The New York office has responsibility for the largest concentration of SEC-registered financial institutions, including more than 4,000 investment banks, investment advisers, broker-dealers, mutual funds, and hedge funds.

Before serving at the Commission, Mr. Berger was global co-head of Ropes & Gray LLP’s Securities and Futures Enforcement Practice.  His practice focused on white-collar criminal defense, regulatory enforcement, and internal investigations. 

From 2002 to 2014, Mr. Berger served as an Assistant U.S. Attorney in the Southern District of New York, including serving as Chief of that office’s Securities and Commodities Fraud Task Force.  In that role, he supervised the investigation and prosecution of some of the nation’s highest profile financial and investment fraud cases, including the largest crackdown on hedge fund insider trading in U.S. history.  As a prosecutor, Mr. Berger also personally investigated and tried a wide variety of cases involving securities and commodities fraud, as well as other crimes.

Mr. Berger earned his bachelor’s degree with distinction from Cornell University in 1996 and his law degree from the University of Virginia School of Law in 1999.  Before joining the U.S. Attorney’s Office in Manhattan, he served as a law clerk for the Honorable Richard M. Berman of the U.S. District Court for the Southern District of New York.


Michael J. Osnato, Jr., former Chief of the Complex Financial Instruments Unit of the Securities and Exchange Commission’s Enforcement Division, is a Litigation Partner and member of the Firm’s Government and Internal Investigations Practice. He focuses on high-stakes regulatory and criminal matters, government investigations, sensitive whistleblower complaints and SEC examination and compliance counseling.

During his tenure at the SEC, Mike led a specialized, nationwide unit of 45 attorneys and former Wall Street professionals in the SEC’s investigations related to complex financial products and practices involving sophisticated market participants. Under Mike’s leadership, the CFI Unit was charged with developing innovative and streamlined methods for monitoring and investigating products and risks that posed a large-scale risk to the securities markets. He supervised investigations and litigations involving the structuring, sale, trading and valuation of derivatives, asset-backed securities and other complex securities by banks, asset managers and public companies, including:         

  • Global financial institution in violations of SEC Customer Protection Rule culminating in historic $415 million penalty
  • Fraud and internal controls cases against traders and global financial institution arising from six billion dollar derivatives trading loss
  • SEC’s first fraud cases against bank issuers of complex derivative products
  • First SEC fraud charges against major credit rating agency
  • Disclosure and controls violations by financial institutions arising from multibillion-dollar regulatory capital overstatements
  • Fraud case against senior-most investment bankers charged for financial crisis-related conduct

At the SEC, Mike was a member of various national leadership Committees, including the Enforcement Division’s Cooperation Committee, which oversees the SEC’s Cooperation Program for entities and individuals subject to SEC investigation. During his tenure on the Cooperation Committee, Mike played a leadership role in developing innovative uses of the Enforcement Division’s Cooperation Program and formulating national policy relevant to the resolution of high-stakes matters. Mike has extensive experience in evaluating the strength of corporate compliance and controls programs, the adequacy and value of corporate and individual cooperation in SEC matters, and has played a lead role in several of the SEC's most prominent settlements involving admissions of wrongdoing.

Throughout his tenure at the SEC, Mike worked in close partnership with multiple domestic and international law enforcement agencies, including the Department of Justice, FBI, CFTC, Federal Reserve, the Manhattan District Attorney's Office, the New York Attorney General's Office, the Office of the Comptroller of the Currency and the U.K. Financial Conduct Authority.

Mike first joined the SEC’s Enforcement Division in September of 2008 as a staff attorney. Prior to his promotion to Chief of the CFI Unit, he served as Assistant Regional Director in the SEC’s New York Regional Office from 2010 through January 2014, where he supervised a number of prominent financial crisis, accounting fraud and investment adviser investigations. 

Mike frequently speaks at conferences on subjects relating to securities enforcement, regulatory developments and private fund enforcement. He also serves as Visiting Lecturer at a prominent European university on the SEC's regulatory and enforcement processes.

Prior to his tenure at the SEC, Mike was an attorney at two prominent international law firms. He received his J.D. with Honors in 1997 from Fordham Law School, where he was a member of the Law Review, and his B.A. with Honors from Williams College in 1994, where he was a Distinguished Scholar.


Nancy Swift recently joined Wells Fargo’s Regulatory Compliance Risk Management team as the Deputy Chief Compliance Officer for Institutional & Brokerage.  In that role, Nancy is responsible for overseeing the portfolio of compliance risk management programs for the institutional, capital markets, securities and brokerage activities across the enterprise.  

Prior to joining Wells Fargo in August, Nancy spent 10+ years at Deutsche Bank, working in a variety of roles in the Legal and Compliance Departments.  For the last three years, she was Head of Compliance for Deutsche Bank’s Markets division, served as co-chief compliance officer for its broker-dealer and supported DB’s implementation of Title VII and the Volcker Rule.

Before joining Deutsche Bank, Nancy spent 3 years in the Legal Department at Credit Suisse First Boston.  Prior to CSFB, Nancy worked as an associate in the litigation department at Simpson Thacher and Bartlett.   

Nancy earned an undergraduate degree from Princeton University, and a law degree from Harvard Law School.  She is admitted to the NY bar and holds the Series 7, 14 and 66 licenses. 


NEAL SULLIVAN, a member of the Firm’s Executive Committee, is co-leader of Sidley’s Securities & Derivatives Enforcement and Regulatory practice, which received the 2016 Chambers USA Award for “Financial Services and Securities Regulation.” Neal conducts a comprehensive securities regulatory and enforcement practice in which he represents broker-dealers, investment banks, investment advisers, accounting firms, public companies, and senior corporate officers before the SEC, DOJ, DOT/FinCEN, PCAOB, FINRA, state attorneys general and securities regulators in private and public investigations and enforcement proceedings and in connection with international securities regulatory matters. He has been recognized in the areas of Securities Regulation and Enforcement since 2008 in Chambers USA: America’s Leading Lawyers for Business, where he has been described as “the epitome of a ‘wise counselor,’” with “significant credibility with the regulators and a keen sense of what all parties need to accomplish to reach resolution.”

A dynamic and effective enforcement counsel, Neal has represented financial services clients in many of the SEC’s major Wall Street investigations in the past 15 years, including anti-money laundering, insider trading, the sale of auction-rate securities, other structured products and various subprime mortgage-related matters; mutual fund market timing. He has represented public companies and accounting firms in connection with SEC investigations and proceedings related to audit work papers, accounting treatment of assets and valuations, compliance with Regulation FD and accounting treatment in connection with M&A.

Neal is also one of the leading advisers to the securities industry on major compliance and regulatory matters. He has played a central role in many significant matters over the past 20 years, such as representing Freddie Mac in a multi-year investigation by the SEC and the DOJ regarding sub-prime mortgages, representing Morgan Stanley in obtaining regulatory approvals for the 2009 launch of Morgan Stanley Smith Barney, the country’s largest retail broker-dealer and in its subsequent move to self-clearing and the Boston Options Exchange’s 2012 filing with the SEC to become a national self-regulatory organization. He represented the settling banks in negotiating the NASAA model settlement that become the basis for the Global Settlement Relating to Firm Research and Investment Banking Conflicts of Interest announced by the SEC, NASD, NASAA, NYSE and the N.Y. Attorney General’s office in April 2003.

During his tenure as the executive director of the North American Securities Administrators Association, he represented the 53 states and territories in negotiations concerning The National Securities Markets Improvement Act of 1996 and was one of the principal drafters of NSMIA. He also served as chief of the Massachusetts Securities Division and was vice president of regulation at the Boston Stock Exchange.

Neal appears regularly on industry and legal panels that address issues of concern to the securities industry, including the SIFMA C&L annual meeting and certain SIFMA regional meetings. He has co-chaired the Fall PLI course on broker-dealer regulation annually since 2007. He also speaks at FINRA’s fall and spring annual conferences.  He has appeared before the U.S. Congress to provide testimony on various SEC proposals and proposed federal oversight of the U.S. capital markets. He has authored several published articles on regulation of broker-dealers.


SUSAN MERRILL assists broker-dealers, investment advisers, financial institutions, exchanges and Fortune 500 companies across the U.S. in investigations before the SEC, CFTC, FINRA and state securities regulators. Susan also conducts internal investigations and advises clients on regulatory compliance matters.

Susan is the former head of enforcement at FINRA, where she oversaw the establishment and development of its enforcement program. She joined FINRA from her position as enforcement chief at New York Stock Exchange Regulation when it merged with the NASD in 2007. Before she became a regulator, Susan was in private practice for 17 years and represented clients in some of the highest-profile matters on Wall Street.

Strong leadership on behalf of her clients has earned Susan many accolades from leading publications. Chambers USA noted “The ‘very knowledgeable’ Susan Merrill is praised for the ‘good practical and strategic advice’ which she is able to offer to broker-dealer clients.” Other major awards include: 

Law360’s 25 Most Influential Women in Securities Law: The profile showcases many of the highlights of her career, including having served as the Financial Industry Regulatory Authority’s first head of enforcement and establishing the Credit for Cooperation policy at the New York Stock Exchange.

The Best Lawyers in America – Securities Regulation (2013–2017)

The Legal 500 US - Financial services: litigation (2013–2017)

Chambers USA: America’s Leading Lawyers for Business — Financial Services Regulation: Broker-Dealer (Enforcement) (2013–2017)

Chambers USA: America’s Leading Lawyers for Business — Financial Services Regulation: Broker-Dealer (Compliance) (2012) 


William R. Baker, III is a partner in the Washington office of Latham & Watkins.  For almost three decades, first as a senior officer at the SEC, and then at Latham, Mr. Baker has worked on some of the most significant securities regulatory and corporate governance matters. Today, he represents financial institutions, corporations, auditing and other professional firms in SEC and other regulatory enforcement proceedings.  In addition, Mr. Baker conducts internal investigations on behalf of management and boards of directors. He regularly counsels clients on SEC reporting, disclosure, compliance and corporate governance requirements.

Prior to joining Latham, he served as Associate Director of the SEC’s Division of Enforcement where he was responsible for supervising all types of SEC enforcement activities, including investigations involving issuer accounting fraud and other disclosure violations, insider trading, market manipulation and broker-dealer and investment adviser misconduct. Mr. Baker led numerous high-profile investigations that resulted in several landmark enforcement actions, including the SEC's action against WorldCom Inc., involving one of the largest financial frauds in history. While at the Commission, he was a recipient of the SEC's Stanley Sporkin Award, awarded by the Chairman of the SEC in recognition of outstanding contributions to the Enforcement program, and of the Commission's Law and Policy Award.

Mr. Baker is consistently recognized as a leading securities lawyer by Chambers USA and The Legal 500 US and is listed as one of the Best Lawyers in Washington by Washingtonian magazine. In 2017, he was named to BTI Consulting Group’s “Client Service All-Star List,” which recognizes national leaders in superior client service identified directly by corporate counsel and executives. He is the co-author of "Corporate Internal Investigations after Sarbanes-Oxley" published in Volume II of The Practitioner's Guide to the Sarbanes-Oxley Act (American Bar Association 2005) and is a contributor to Securities Law Techniques (Matthew Bender). He was named to the Securities Docket 2017 "Enforcement 40" list, which lists the forty leading securities enforcement defense attorneys.

Mr. Baker is a Trustee of the SEC Historical Society.  Previously, he was an adjunct professor at George Washington University Law School, where he taught Securities Regulation. He is a frequent author, speaker and panelist on securities law issues at programs organized by a wide variety of groups, including the American Bar Association, the District of Columbia Bar Association, the Association of the Bar of the City of New York, SIFMA, the Justice Department's National Advocacy Center, the Practicing Law Institute, Georgetown University Law Center and Stanford Law School. 


Christopher J. Mahon is a senior vice president and head of broker-dealer legal and regulatory at AllianceBernstein, where he manages the legal and compliance functions globally for its institutional broker, Bernstein.  He serves on AB’s enterprise-wide ethics, conflicts, and internal control committees as well as other of its risk, governance and policy committees.

Chris is a member of the Compliance Advisory Committee of the U.S. Financial Industry Regulatory Authority, FINRA.  He is a former member of FINRA’s National Adjudicatory Council, serving as its Vice Chair in 2015, and of FINRA’s International Advisory Working Group.  Chris is a current member and former co-chair of the Securities Industry and Financial Markets Association’s Compliance and Regulatory Policy Committee.  He is an executive officer of SIFMA’s Compliance and Legal Society, contributing to the group’s various policy, advocacy and educational efforts.  He chaired C&L’s annual conference in 2016.

Chris is an adjunct faculty member at Fordham University’s Gabelli School of Business, where he teaches a course on financial regulation, compliance, and risk management.

Previously, Chris was a managing director at Deutsche Bank, where he held senior global and regional roles in equities and investment banking compliance.  He also was the director of compliance and counsel at D.E. Shaw & Co.  Chris served as a senior counsel in the U.S. Securities and Exchange Commission’s Division of Enforcement and was an associate in litigation and antitrust at Cadwalader.  Chris is a graduate of New York University School of Law, where he was an editor-in-chief of the Annual Survey of American Law.  He is a summa cum laude graduate of Rutgers College.


JAMIE BRIGAGLIANO is a partner in the Securities & Derivatives Enforcement and Regulatory group. He advises broker-dealers and hedge funds on a broad variety of regulatory, enforcement, compliance, and transactional matters. Jamie focuses his practice in particular on SEC and Finra rules governing trading by broker-dealers and hedge funds, and broker-dealer registration and conduct rules. Among those areas in particular are rules governing: Short Sales (Regulation SHO and Rule 105), Research, Regulations M, NMS, and ATS, Order Handling, and Best Execution. Jamie’s practice is recognized by Chambers USA (Band 2) and The Best Lawyers in America (Securities Regulation). In the 2016 edition of Chambers USA,  Jamie “ is described as ‘extremely knowledgeable and helpful" and "a very smart trading lawyer’ by interviewees, who point to his impressive regulatory compliance work with broker-dealers, hedge funds and other financial institutions as evidence of his growing prominence within the industry.”


Mr. Citera is Managing Director and Associate General Counsel at J.P. Morgan Chase & Co.  He manages the cash equities legal team providing legal, regulatory and compliance advice to the Equities Sales and Trading Desks in the Corporate and Investment Bank.  Previously, he was Counsel in the Financial Institutions Group at Davis Polk & Wardwell and one of the senior lawyers in that firm’s Trading and Markets Practice.  Before joining Davis Polk, Mr. Citera served as Deputy General Counsel at PaineWebber Securities and Regulatory Risk Manager for the U.S. Equities Division of UBS Investment Bank.  Earlier in his career, he was an attorney in the SEC’s Division of Market Regulation and Office of General Counsel and Special Counsel at the law firm Wilmer, Cutler & Pickering.   Mr. Citera has been a guest lecturer at the Rockefeller College of Public Administration at SUNY Albany, the University at Buffalo Law School, Albany Law School and Cordoza Law School.  He serves on the Dean’s Advisory Board to Rockefeller College and on the Advisory Council for the Institute of Financial Market Regulation at SUNY Albany.  Mr. Citera obtained his J.D. degree from the University at Buffalo Law School and his B.A. from the State University of New York at Albany.