Steffen regularly counsels clients on federal and state broker-dealer regulatory matters and applicable self-regulatory organization (“SRO”) matters; US Securities and Exchange Commission (“SEC”) financial responsibility rules, including SEC Rule 15c3-1, as well as SEC Rule 15c3-3 and custody issues arising thereunder; custody arrangements with domestic and foreign custodians, including the negotiation of custody agreements; broker-dealer registration/formation, including structural advice, and SRO membership (FINRA, exchanges and clearing agencies); successor registration; material changes in business operations/business expansions; merger/acquisition/restructuring transactions; business transfers/consolidations; joint ventures; registration and qualification of personnel (state/SRO); foreign broker-dealer/cross-border issues under SEC Rule 15a-6 and “chaperoning” arrangements thereunder; broker-dealer “status” questions; books and records requirements; regulatory reporting and disclosure obligations; vendor/outsourcing relationships; compliance and operational systems/technologies; product development; FINRA advertising issues; digital platforms, including mobile trading apps, and digital engagement practices, including the use of predictive data analytics/artificial intelligence by broker-dealers; SEC risk assessment requirements (Form 17-H filings); and Bank Secrecy Act/Anti-Money Laundering and Office of Foreign Assets Control compliance.
Steffen also advises financial services firms and fintech companies on securities and broker-dealer regulatory matters relating to digital assets and blockchain technology, including business expansion and broker-dealer registration and custody issues.
Steffen is ranked as a leading lawyer by Chambers USA 2024 for Financial Services: Broker Dealer (Compliance). Clients described Steffen as “efficient and effective… particularly vis-à-vis FINRA rules and processes” to Chambers USA. The Legal 500 US 2024 recommends Steffen for Financial Services Regulation, noting he “counsels broker-dealers on SEC regulations and those concerning blockchain and other digital assets.” The IFLR1000 also ranks Steffen as a “Notable Practitioner” for Financial Services Regulatory.
