Washington, District of Columbia, United States
With more than 10 years of experience representing and advising financial services firms and public companies on matters relating to the regulation of securities, annuities, insurance and retirement products and services, I have developed a strong analytical ability to understand my clients’ needs and goals, and to formulate and implement effective strategies to achieve their business objectives. In addition to my technical experience as a practitioner, I have spent several years as a government affairs professional for a diverse financial services enterprise. In this capacity, I was extensively involved with a number of critical legislative and regulatory initiatives affecting the financial services / wealth management industry. Through this uncommon combination of experiences, I have developed a unique skillset and perspective that enables me to deliver an unparalleled level of service to help my clients achieve their business objectives. Areas of Expertise • Securities (8+ yrs) – Federal Securities Laws (’33,’34 Act and ’40 Acts, Sarbanes-Oxley Act, Dodd-Frank Act); SEC and FINRA Regulations; State Blue Sky Laws and Rules • Annuities and Insurance (5+ yrs) – NAIC Models; State Laws and Regulations • Retirement Plan Products and Services (5+ yrs) – ERISA and DOL Regulations; Tax Qualification Requirements under Internal Revenue Code and Treasury Department Regulations • Corporate Law (5+ yrs) – Mergers & Acquisitions, Joint Ventures and other Corporate Transactions; Corporate Governance Admitted to Practice in Connecticut and New York
Over the past several years, I played a leading role in the development of The Hartford's positions on and strategic responses to a number of issues of critical importance to the company's retirement plans, global annuity, mutual fund and broker-dealer businesses, including the DOL’s definition of fiduciary proposal, the DOL’s rules for the use of electronic delivery, the DOL and Treasury's joint lifetime income initiative, the SEC's uniform standard of care initiative, the industry's work on a variable annuity summary prospectus, and the SEC and CFTC's joint efforts to implement the derivatives provisions in the Dodd-Frank Act. While the final book on these matters has yet to be written, the industry has made meaningful progress towards positive outcomes. As The Hartford’s representative, I played a significant role in these industry efforts to ensure that the ultimate goals and the strategies employed to achieve them remained consistent with the company’s priorities.
In my early days as a member of The Hartford’s Government Affairs team, I spent much of my time on annuity suitability regulation. I worked with ACLI, the Committee of Annuity Insurers, and other trade associations on the development of FINRA’s variable annuity suitability rule (now known as Rule 2330) and on modifications to the NAIC’s Suitability in Annuity Transactions Model Regulation. After a long and challenging process, we were successful in helping FINRA and the NAIC to adopt final rules that did not unduly interfere with The Hartford’s and the industry’s standard business practices, while achieving the regulators’ goal of enhancing consumer protection.
With nearly five years of law firm experience under my belt, I decided to take on the challenge of going in-house with one of the largest aircraft engine manufacturers in the world. My time with Pratt & Whitney was relatively brief, but it provided a solid foundation for my transition into corporate America.
At Edwards & Angell, I primarily represented insurance industry clients and quickly discovered within myself an ability to adapt and achieve success in new areas of the law. I conducted 50-state surveys on a variety of state insurance law issues, and was the lead associate for a privately-held life settlement company in connection with more than 10 secondary market acquisitions of life insurance policies. My practice was not limited to insurance, though, as I also represented and advised clients on several corporate and securities matters, including the operation of a global employee share purchase plan by a large foreign private issuer and a $13 million stock acquisition.
While my time with Paul Hastings was professionally and intellectually rewarding and stimulating, I left the firm and re-located to the Hartford area during the summer of 2003. I joined Schatz & Nobel as a contract lawyer on an interim basis while I sought more permanent employment, and was part of a team of attorneys reviewing evidence for litigation involving a high-profile corporate scandal.