C. Dirk Peterson

Drawing on his experience in government service and over 25 years of private practice at two global Am-Law 100 firms, clients look to Mr. Peterson for counsel on a broad range of federal and state securities-regulatory matters.

Mr. Peterson routinely represents financial institutions and trade associations before the United States Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), the New York Stock Exchange (NYSE), and various state securities commissions on a variety of regulatory matters, including the financial responsibility rules of the SEC, business approvals prescribed by FINRA and the NYSE, the extent of pre-emption of state investment adviser regulations pertinent to SEC-registered investment advisers, and for purposes of commenting on SEC and SRO rulemakings.

He specializes in advising financial institutions on securities regulatory issues related to, among other things: (1) registration of broker-dealers, investment advisers, municipal securities advisors, and transfer agents, (2) distribution and sales platforms, (3) implementation of effective information barriers across an integrated financial services organization, (4) standards of sales-practice and fiduciary conduct, (5) changes of ownership and control of regulated firms, (6) approvals for material business expansions instituted by regulated firms, (7) implementation of compliance controls and written policies and procedures, (8) permissible soft-dollar arrangements, (9) cross-border matters, including the permissible reliance on an exemption for foreign broker-dealers to offer and sell securities in the United States, and (10) navigating SEC and SRO regulatory examinations. He also advises and opines on broker-dealer, investment adviser, and investment company status issues.

Prior to entering private practice, Mr. Peterson was associated with the SEC’s Division of Trading and Markets, Office of Chief Counsel, where he participated in rulemakings under, and regulatory interpretations of, provisions of the Securities Exchange Act of 1934. During his tenure with the SEC, Mr. Peterson was the recipient of the Chairman’s Award for Excellence for his participation in the municipal securities market reform initiatives of then Chairman Arthur Levitt.