Elizabeth J. Hogan Partner

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Elizabeth Hogan (“Lizzie”) is the managing partner of the Washington office and co-chair of the firm’s Securities Enforcement & Regulatory Counseling practice group. As the former senior vice president and leader of Market Regulation Enforcement at the Financial Industry Regulatory Authority (FINRA), Lizzie has unique insight into the priorities and procedures of financial services regulators, including the SEC, FINRA, the exchanges, and state securities regulators and attorneys general. Lizzie represents clients in complex securities matters, focusing on investigations, regulatory enforcement proceedings, and litigation.

In her role as a FINRA officer, Lizzie coordinated with other financial regulators on issues and conduct that presented significant risk to the integrity of the U.S. markets, as well as efforts to reduce regulatory duplication. She led a national team of specialized attorneys and also created the order routing task force within Market Regulation Enforcement to handle complex matters addressing potential conflicts of interest and best execution concerns stemming from broker-dealers’ practices of routing customer order flow.

Prior to her tenure at FINRA, Lizzie was a seasoned attorney at a prominent national law firm for more than a decade defending clients in high-stakes government investigations. She has extensive expertise regarding electronic trading rules and broker-dealer regulation, including market access, order protection, customer protection, best execution, and the anti-fraud and manipulative trading provisions.

Lizzie is ranked by Chambers USA for Financial Services Regulation: Broker Dealer (Enforcement), Nationwide, where she is praised by clients for her “very strong commercial focus and technical ability,” “knowledge of the market and knowledge of the regulatory hot topics,” and “amazing view into FINRA’s enforcement priorities and processes.” She is also recognized by The Best Lawyers in America for Securities Regulation.

Lizzie served as a law clerk for the Honorable Jack B. Jacobs of the Delaware Supreme Court from 2005-2006.

Experience

  • Defended multiple parallel investigations by FINRA, the SEC, the exchanges and the Office of the New York Attorney General, involving high profile market structure-related issues and concerns on behalf of a multi-national financial institution and registered broker-dealer.
  • Represented a multi-national financial institution in parallel investigations by multiple federal and state regulators related to the underwriting and issuance of mortgage-backed securities. Served as lead liaison to individual counsel for more than 20 current and former employees from the same institution in both civil and criminal investigations.
  • Represented the former Chairman and CEO of Countrywide Financial Corporation in the SEC’s investigation and civil suit against him arising from the financial crisis.
  • Represented a multi-national financial institution in overlapping investigations by the FRB, OCC, SEC, DOJ and FSA into losses stemming from outsized credit default swap positions.
  • Defended a low latency trading firm in a SEC investigation of its compliance with the net capital rule.
  • Represented a broker-dealer in a FINRA investigation into its client’s trading behavior at the close and compliance with the know-your-client rules.
  • Defended a Department of Defense inquiry stemming from a whistleblower complaint alleging violations of the False Claims Act.
  • Conducted an internal investigation in the U.S. and Switzerland on behalf of a multi-national pharmaceutical company involving whistleblower claims alleging accounting fraud and navigated international privacy laws in the course of that investigation.
  • Defended a SEC investigation of a major motion picture house into potential Foreign Corrupt Practices Act violations involving the Chinese movie industry.
  • Represented a multi-national financial institution in an investigation into offshore tax havens before the U.S. Senate Permanent Subcommittee on Investigations.