Neal E. Sullivan

He has been recognized in the areas of Securities Regulation and Enforcement since 2008 in Chambers USA: America’s Leading Lawyers for Business, where he has been described as “the epitome of a ‘wise counselor,’” with “significant credibility with the regulators and a keen sense of what all parties need to accomplish to reach resolution.”

A dynamic and effective enforcement counsel, Neal has represented public companies and accounting firms in connection with SEC investigations and proceedings related to audit work papers, accounting treatment of assets and valuations, compliance with Regulation FD and accounting treatment in connection with M&A, whistleblower matters, and internal investigations on topics as varied as FCPA in Latin America, off shore funds and U.S. tax restrictions and anti-money laundering.

Neal is also one of the leading advisers to the securities industry on major compliance and regulatory matters. He has played a central role in many significant matters over the past 20 years, such as representing Freddie Mac in a multi-year investigation by the SEC and the DOJ regarding sub-prime mortgages, representing Morgan Stanley in obtaining regulatory approvals for the 2009 launch of Morgan Stanley Smith Barney, the country’s largest retail broker-dealer and in its subsequent move to self-clearing and the Boston Options Exchange’s 2012 filing with the SEC to become a national self-regulatory organization. He represented the settling banks in negotiating the NASAA model settlement that become the basis for the Global Settlement Relating to Firm Research and Investment Banking Conflicts of Interest announced by the SEC, NASD, NASAA, NYSE and the N.Y. Attorney General’s office in April 2003. 

During his tenure as the executive director of the North American Securities Administrators Association, he represented the 53 states and territories in negotiations concerning The National Securities Markets Improvement Act of 1996, and was one of the principal drafters of NSMIA. He also served as chief of the Massachusetts Securities Division, one of the most active state securities regulators in the United States; and was vice president of regulation at the Boston Stock Exchange.

Neal appears regularly on industry and legal panels that address issues of concern to the securities industry, including the SIFMA C&L annual meeting and certain SIFMA regional meetings. He also speaks at FINRA’s fall and spring annual conferences. He has appeared before the U.S. Congress to provide testimony on various SEC proposals and proposed federal oversight of the U.S. capital markets. He co-chaired the Fall PLI course on broker-dealer regulation in New York City annually from 2007 through 2017. He has authored several published articles on regulation of broker-dealers.

Awards

• Law360 MVP, Compliance (2020)
• Chambers USA: America’s Leading Lawyers for Business — Financial Services Regulation: Broker-Dealer (Compliance); Securities: Regulation: Enforcement (2008–2022) 
• Leading Lawyer in Securities Law, The Best Lawyers in America (2009–2019)