John Ayanian is co-chair of McGuireWoods’ Securities Enforcement & Regulatory Counseling practice group and advises clients on broker-dealer and securities market regulatory matters.
He has substantial experience advising broker-dealers, including retail, institutional, and clearing broker-dealers on a wide range of regulatory and compliance obligations under the Securities Exchange Act of 1934 and SEC, FINRA, and MSRB rules impacting their respective businesses. He regularly advises clients on broker-dealer status issues, Regulation Best Interest, Form CRS, conflicts of interest, disclosures, advertising, the distribution of investment products and investment research, trading issues, best execution obligations, and SEC and FINRA registration issues, and digital engagement practices. John also has significant experience on issues involving broker-dealers’ obligations under net capital and customer protection rules, market structure, regulatory matters involving mergers and acquisition transactions, as well as issues involving the use of money market and bank deposit sweep programs.
Prior to joining McGuireWoods, John served as the co-chair of a national law firm’s financial services industry initiative, the practice leader for the firm’s broker-dealer regulatory practice, as well as the Washington, D.C. office managing partner. He was vice president and assistant general counsel with a national bank holding company, where he worked with its broker-dealer subsidiaries. He also served as a staff attorney and Special Counsel in the SEC’s Division of Market Regulation, Office of Market Supervision, where he was responsible for the regulation of trading and markets.
- Represented a major U.S. financial institution on regulatory aspects of numerous broker-dealer acquisitions.
- Advised broker-dealers in connection with implementation of disclosures and compliance programs in response to Regulation Best Interest.
- Advised numerous broker-dealers in connection with the development of their respective cash sweep programs.
- Counseled an industry trade association on issues involving clearing broker-dealers.
- Advised an industry trade association on advocacy before the SEC in connection with amendments to Rule 15c3-3 involving cash sweep programs.
- Advised an industry trade association on advocacy relating to the regulation of outsourced activities of broker-dealers.
- Represented a non-U.S. securities and derivatives market as regulatory counsel in connection with the first-ever acquisition of a U.S. registered national securities exchange by a foreign entity.
DePaul University College of LawJD
Executive Editor, DePaul Business Law Journal1993
- University of MichiganBA1990
Recognized, The Best Lawyers in America, Securities/Capital Markets Law, 2022, 2023, 2024; Securities Regulation; 2024; Woodward/White, Inc.
Ranked, Financial Services Regulation: Broker Dealer (Compliance), Nationwide, Chambers USA, 2009–2023
Selected for inclusion in “Legal 500 United States,” Corporate Investigations and White-collar Criminal Defense, 2022
- Author, SEC Issues Risk Alert on Reg BI Deficiencies Identified During Exams, McGuireWoods Legal Alert, February 2, 2023
- Author, Broker-Dealer and Investment Adviser Account Recommendations, Subject to Inquiry, July 19, 2022
- Author, FINRA Releases 2022 Report on Examination and Risk Monitoring Program, McGuireWoods Legal Alert, March 15, 2022
- Author, Federal Framework for Digital Asset Regulation Comes into Focus, Consumer FinSights, March 15, 2022
- Author, SEC Onslaught of Proposed Rules Turns Focus to Investment Advisers, McGuireWoods Legal Alert, February 24, 2022
- Author, SEC Speaks 2021: New Enforcement Director Resolves to Restore Public Trust, Empower Staff, McGuireWoods Legal Alert, October 25, 2021
- District of Columbia
- Panelist, "Compliance Coverage Away from the Front Office (Non-Revenue Functions)", SIFMA C&L Annual Seminar, March 15, 2023
- Panelist, "WA: Remote Working: What Have We Learned?", SIFMA CL Annual Seminar, Orlando, FL, March 20-23, 2022
- Panelist, Government Regulatory and Enforcement Outlook 2022, March 16 & 17, 2022