Photo of Louis D. Greenstein

Louis is a member of the firm’s Financial Services & Securities Enforcement Department. For more than 20 years, Louis has represented financial services firms, corporations, their boards, officers, directors and employees in investigations by the SEC, FINRA, the United States Department of Justice, and state regulatory agencies. Louis also has substantial experience conducting internal investigations and counseling clients on corporate governance and disclosure issues, including strategies for avoiding potential regulatory issues through preventive remedial measures. Prior to entering private practice, Louis worked in the SEC’s Enforcement Division, where he conducted investigations to evaluate and enforce compliance with the federal securities laws. He also participated in the prosecution of civil and administrative enforcement actions.

The Securities and Exchange Commission continues to propose rules at a rapid pace. Three of the most recent proposed rules would significantly impact investment advisers by:

  1. Requiring documentation of registered investment adviser compliance reviews;
  2. Establishing cybersecurity risk management and reporting requirements for investment advisers, investment companies and business development companies;
  3. Updating and accelerating beneficial ownership

On Feb. 3, 2015, the Securities and Exchange Commission (SEC) published a Risk Alert summarizing observations gleaned from a cybersecurity examination sweep of 57 registered broker-dealers (BDs) and 49 registered investment advisers (IAs). The examination sweep followed an April 2014 announcement that the SEC’s Office of Compliance Inspections and Examinations (OCIE) 2014 Examination Priorities included