KEVIN J. CAMPION is a partner in the Washington, D.C., office of Sidley Austin LLP. He advises a wide array of financial services firms including investment and commercial banks, broker-dealers and hedge funds – on a broad variety of regulatory, enforcement, compliance, and transaction matters. Mr. Campion focuses his practice in particular on broker-dealer and market regulation matters, with particular emphasis upon regulations governing short sales (Regulation SHO), short interest reporting, Regulation M, research analyst conflicts, FINRA advertising rules, clearance and settlement, and broker-dealer registration and compliance issues. Mr. Campion also regularly assists advisers and hedge funds with trading questions and long and short position disclosure requirements, including the requirements of Section 13(d), 13(f) and Section 16. He also assists clients, mostly clearing firms and prime brokers, in the defense of SEC, FINRA, NYSE and state enforcement actions and investigations, as well as securities law class actions. Mr. Campion has represented the Securities Industry Financial Markets Association with respect to comment letters submitted to the SEC, and in obtaining a variety of no-action letters from the SEC Staff relating to Regulation SHO and Rule 10a-1, including working with the SIFMA Prime Brokerage Committee on the new Prime Broker Letter.
Prior to joining the firm, Mr. Campion worked for over four years with the Securities and Exchange Commission’s Division of Market Regulation. During his time with the SEC, Mr. Campion was responsible for administering and interpreting rules and regulations governing issuers, broker-dealers, and other market participants in connection with the offering, trading, and settlement of equity, debt, and derivatives. He also was responsible for analyzing requests for exemptive relief in connection with cross-border mergers and acquisitions and was consulted often by the Division of Enforcement to assist with investigations into violations of rules governing the offering and trading of securities. Mr. Campion assumed a leading role in several rulemaking initiatives, including new short sale regulation under Regulation SHO, Interpretive Guidance on Married Put Transactions, Decimalization, Regulation NMS, and the SEC’s Hedge Fund Report.
Mr. Campion is a frequent speaker at securities industry conferences and has written prior articles related to short sale regulations, securities lending, and beneficial ownership reporting requirements. Mr. Campion has been recognized annually in Chambers USA: America’s Leading Lawyers for Business since 2011 in the area of Financial Services Regulation: Broker Dealer (Compliance; Nationwide).
Mr. Campion’s team has received recognition for its work on complex matters, most recently when the firm was named the U.S.News – Best Lawyers “Law Firm of the Year” in Securities Regulation. The firm also received the most first-tier national rankings, including Securities Regulation, of any U.S. law firm in the 2011/12 U.S.News – Best Lawyers “Best Law Firms” survey.