Todd’s practice focuses on regulatory enforcement defense. He represents financial institutions, broker-dealers, investment advisers, hedge funds, audit firms, public companies, and corporate officers in connection with regulatory and enforcement inquiries by the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ), Financial Industry Regulatory Authority (FINRA) and other self-regulatory organizations (SROs), the New York State Department of Financial Services, the Federal Reserve Bank of New York, and other federal and state regulators.
Prior to joining McGuireWoods, Todd was a Chief Counsel in FINRA’s Enforcement Department. Todd focused on matters emanating from FINRA’s Market Regulation team with whom he worked closely to resolve matters involving the Market Access Rule, Best Execution, Regulation SHO, market manipulation, and trade reporting rules, among others. Todd brought matters involving these and other rules on behalf of FINRA and other SROs, including the New York Stock Exchange, Cboe, and Nasdaq.
Prior to his tenure at FINRA, Todd was a partner with an international law firm where he focused on securities enforcement and regulatory defense matters. He served as a law clerk to the Hon. Richard K. Eaton of the U.S. Court of International Trade from 2005-2007.
- Represented a broker-dealer in the largest enforcement action brought by the SEC involving compliance with the customer protection rule (Rule 15c3-3).*
- Represented a large financial institution in an SEC inquiry regarding asset-backed securities trading and TRACE reporting.*
- Represented a large financial institution in responding to separate government inquiries regarding secondary mortgage backed securities trading.*
- Represented a large financial institution in responding to separate government inquiries regarding FX trading business.*
- Represented investment advisers in connection with government inquiries regarding insider trading and other issues.*
- Represented a large investment adviser in a SEC inquiry regarding marketing disclosures and valuation of illiquid securities.*
- Represented a U.S. insurance company in responding to inquiries from the New York State Department of Financial Services.*
- Represented a financial institution in an SEC investigation regarding synthetic collateralized debt obligations squared.*
- Represented a financial institution in a FINRA inquiry regarding broker-dealer anti-money laundering surveillance and reporting requirements.*
* Experience handled prior to joining McGuireWoods.
Albany Law SchoolJD
magna cum laude2005
- Panelist, "Litigation and Regulatory Enforcement: Perspectives from External Counsel, In-House Counsel, and Regulators", SIFMA Compliance & Legal Society New York Regional Seminar, October 19, 2023
- Hon. Richard K. Eaton, U.S. Court of International Trade, 2005-2007
- New York
- U.S. District Court for the Southern District of New York
- Co-author, Principal Lessons of the Jesse Litvak Securities Fraud Saga, Westlaw Journal, April 2019
- Co-author, ‘Dark Pool’ Trading is Not Shielded from Regulatory Spotlight, New York Law Journal, January 2013
- Contributor, Chapter 10: The Planning Process, Successful Partnering Between Inside and Outside Counsel, Vol. 1 (Supplement), 2011
- Co-author, Analyzing the SEC’s First Deferred Prosecution Agreement, New York Law Journal, July 2011
- Contributor, Chapter 61: Litigation Management by Corporations, Commercial Litigation in New York State Courts, Third Edition, Vol. 4A, 2010
- Co-author, Expert Testimony and Class Certification: The Outcome Determinative Role of Daubert, ALI-ABA, 2008