Finders and Unregistered Broker-Dealers: Understanding the Risks and Recent Developments

Mr. Lacarrubba advises broker-dealers, hedge funds, and other financial institutions on matters arising under the rules of the SEC, CFTC, and various self-regulatory organizations, including the Financial Industry Regulatory Authority (FINRA), the National Futures Association (NFA), and various securities and futures exchanges. He focuses on a wide range of regulatory issues affecting financial services firms, including equity and futures trading practices, alternative trading system regulation, best execution practices and compliance with Regulation SHO, Regulation M, Regulation NMS, and the Market Access Rule.

Ms. Rohrer concentrates her practice in securities broker-dealer regulatory, compliance, enforcement defense, litigation and arbitration matters in the financial services and fintech industries. She advises emerging and established companies on the development, regulation and operation of funding portals, capital raising platforms and trading platforms, including in connection with angel investing, crowdfunding, in the private and public securities markets. Ms. Rohrer’s practice involves all aspects of broker-dealer regulation, including Self-Regulatory Organization membership, cross border transactions and chaperoning of foreign broker-dealers (under SEC Rule 15a-6). She also provides regulatory guidance to investment banking clients in connection with securities offerings and related trading issues. Ms. Rohrer is a leader in the M&A Broker space as one of the six lawyers who authored the request to the SEC for No-Action relief for mergers and acquisition brokers—the M&A Brokers No-Action Letter. The M&A Brokers Letter allows M&A brokers to receive transaction-based compensation without registering as securities brokers with the SEC.