Subject to Inquiry

Subject to Inquiry


Government Investigations and White Collar Litigation Group

William E. Goydan

Photo of William E. Goydan Bill represents clients in complex securities matters, focusing on internal investigations, regulatory enforcement and litigation. In addition to handling investigations and litigation, Bill counsels companies and individuals on compliance with securities industry rules, reporting requirements, best practices, enhancements to policies and procedures, regulatory developments and enforcement trends. Bill also assists clients in training business, compliance and legal department personnel. Bill’s extensive experience includes serving as outside counsel for various national and regional securities firms in the areas of regulatory enforcement, internal investigations, customer arbitrations and employment litigation.

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FINRA Issues New Guidance Regarding Customer Communications Relating to Departing Registered Representatives

Financial Institution Regulation
As recognized by new guidance from the Financial Industry Regulatory Authority (FINRA), the departure of a registered representative often prompts customer questions about the departing representative and the continued servicing of a customer’s account. In light of the continued frequency of movement of registered representatives from, or among, member firms, FINRA issued guidance on April… Continue Reading

SEC Launches Self-Reporting Initiative for Investment Advisers

Enforcement and Prosecution Policy and Trends
In line with Chairman Jay Clayton’s oft-stated priority of protecting the long-term interests of Main Street investors, on Feb. 12, 2018, the Securities and Exchange Commission’s Division of Enforcement announced the launch of a new self-reporting initiative for investment advisers. This new initiative — the Share Class Selection Disclosure Initiative — aims to address undisclosed… Continue Reading

Beware What You Share: Privilege Waiver Risks in Investigations

Enforcement and Prosecution Policy and Trends, Financial Institution Regulation
In responding to regulatory and government investigations, firms are often faced with the question of how to balance the desire to cooperate with the need to preserve privilege over an internal investigation.  Financial institutions face this question additionally in their reporting requirements to regulators, including Form U-5 filings and Suspicious Activity Reports.  Two recent decisions… Continue Reading

SEC Expected to Expedite FCPA Investigations in Light of Kokesh

Anti-Bribery and Corruption, Enforcement and Prosecution Policy and Trends
On November 9, 2017, Steven R. Peikin, Co-Director of the SEC’s Division of Enforcement, delivered a keynote speech at a conference commemorating the 40th anniversary of the enactment of the Foreign Corrupt Practices Act (“FCPA”) in which he reflected on “the past, present, and future” of the SEC’s enforcement of the FCPA. After confirming the… Continue Reading

Proposed Rules Aimed at High-Risk Brokers Confirm FINRA Push for Firms to “Do Their Part”

Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation
Financial Industry Regulatory Authority (FINRA) President and CEO Robert Cook spoke earlier this month at Georgetown University’s McDonough School of Business, where he outlined several proposals to further what he called one of FINRA’s “most important purposes”—“to protect investors from bad actors.”  Taking aim at “those who seek to evade regulatory requirements and harm investors… Continue Reading

U.S. Supreme Court Rules Time Limits Apply to SEC Disgorgement Orders

Enforcement and Prosecution Policy and Trends, Securities and Commodities
A unanimous United States Supreme Court held Monday, in Kokesh v. Securities and Exchange Commission, that the five-year statute of limitations under 28 U.S.C. § 2462 applies to disgorgement sought by the Securities and Exchange Commission. Previously, the Circuits had been split on this issue. The issue in Kokesh was straightforward. Kokesh appealed a trial… Continue Reading

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