Susan Grafton leads Dechert’s Broker-Dealer, Securities Trading and Markets practice and co-leads its FinTech practice. She is consistently ranked nationally by Chambers USA in the Broker-Dealer (Compliance) and Broker-Dealer (Enforcement) categories. Among other comments, clients note her “problem-solving orientation. I find her to be very practical and she can work with us on getting to a positive resolution. She always has her client's goals in mind.” (Chambers USA 2017). Market observers call her “an excellent regulatory attorney” and note that “Susan’s work as always been very impressive.” (Chambers USA 2018). They also note that she is “very well connected in the industry, and is able to get the SEC and FINRA to be more responsive” (Chambers USA 2016). Clients also describe her as “a go-to attorney…especially in Regulation M issues and distribution type questions, [where] she's very knowledgeable” (Chambers USA 2015).
Ms. Grafton counsels a wide range of broker-dealers, including alternative trading systems, on all aspects of their business, including registration and changes in control; sales practices, including proposed Regulation Best Interest; trading and execution issues, including compliance with best execution, trade and order reporting, and Regulation NMS and SHO requirements; and Regulation M and FINRA’s corporate finance rules. Her practice also includes representing investment avisers, including hedge fund managers, on a variety of issues, including broker-dealer status issues and solutions to avoiding broker-dealer registration, the use of expert networks, handling material non-public information, and compliance with Rule 105 of Regulation M. She advises buy-side and sell-side clients on soft dollar issues and intersection between Section 28(e) and MiFID II.
In addition, Ms. Grafton frequently represents clients before the SEC and FINRA in connection with regulatory examinations and enforcement investigations pertaining to a wide range of issues.
Ms. Grafton has a unique combination of regulatory, in-house and law firm experience. She began her career with the SEC’s Division of Trading and Markets, and subsequently served as a vice president and associate general counsel of Goldman Sachs & Co. where she advised on a variety of strategic, regulatory compliance and operational issues related to the firm’s institutional equities sales and trading businesses.