Sidley Austin LLP

W Hardy Callcott

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Practice Areas

Hardy Callcott's practice concentrates on enforcement defense and regulatory counseling concerning securities market and regulatory issues for broker-dealers, investment advisers, mutual funds and others in the financial services industry. He provides securities enforcement defense before the SEC, Department of Justice, FINRA and other SRO and state regulators for members of financial services industry, public companies and officers and directors. He also conducts internal investigations.

Representative enforcement matters include:

Representing senior executive of broker-dealer in SEC investigation of separately managed account trading;

Represented regional broker-dealer in SEC/FINRA investigations of potential cross trades; investigations closed without action Represented consultant in SEC investigation of alleged unregistered municipal advisor activity, settled with de minimis penalty;

Representing public company in SEC investigation of potential “channel-stuffing” activities alleged by whistleblower.

Representative counseling matters include:

Represented national automated investment adviser in SEC exam concerning potential bias toward proprietary products, SEC exam staff dropped proposed finding;

Represented market-making firm in SEC exam concerning potential best execution violations, SEC exam staff dropped proposed finding;

Represented newly formed insurance holding company in obtaining FINRA approval of change in control of broker-dealer;

Represented bank-affiliated broker-dealers in implementation of robo-adviser service.