ANDREW BLAKE advises a wide array of financial services clients on regulatory, transactional, compliance and enforcement matters arising under the jurisdiction of the U.S. Securities and Exchange Commission (SEC), U.S. Commodity Futures Trading Commission (CFTC) and Financial Industry Regulatory Authority (FINRA). He is a member of Sidley’s global Securities Enforcement and Regulatory practice, which received the 2019 Chambers USA Award for Financial Services Regulation, and was named the “Law Firm of the Year” for Securities Regulation in 2020 and 2017 by U.S. News – Best Lawyers.
Andrew focuses his practice on the regulation of financial markets and intermediaries, including clearing organizations, transfer agents, exchanges, trading platforms, broker-dealers, futures commission merchants and private funds. He has deep experience in particular with the options markets and frequently advises clients on regulatory and operational issues regarding the clearance and settlement of equity and debt instruments, evolving regulations for swaps and security-based swaps and participation in central counterparties, depositories and trading platforms. On a regular basis, he also counsels clients on clearing arrangements, customer protection regulations, trading issues and financial contracts.
Representative engagements include:
- Options compliance and examination issues regarding the regulations of the options exchanges, FINRA and the SEC, including LOPR, position and exercise limits, give-up arrangements and exercise and assignment.
- SEC and CFTC rule changes, new derivatives products and central clearing for stock loans.
- Participant rights and obligations in the use of central counterparties, central securities depositories and exchanges.
- Security-based swap and swap regulatory issues regarding implementation of the Dodd-Frank Act by the SEC, CFTC and Federal Reserve Board.
- Clearing agreements for domestic and cross-border relationships and related matters regarding customer accounts and FINRA requirements.
- Transfer agent operations and compliance and examination issues.
- Volcker Rule trading matters regarding derivatives and related policies and procedures.
Andrew formerly served in the Division of Trading and Markets at the SEC. There, he received the Law and Policy Award for his work on implementing Titles VII and VIII of the Dodd-Frank Act regarding the regulation of swaps and enhanced supervision for payment, clearing and settlement activities. Andrew had a leading role in several rule makings, including drafting new rules for clearing agencies and derivatives end-users, and he helped supervise clearing agencies, transfer agents, exchanges, alternative trading systems and broker-dealers. Prior to the SEC, Andrew was in-house counsel at one of the largest U.S. financial complexes, where he advised on broker-dealer matters and negotiated fully disclosed clearing, prime brokerage and securities lending agreements.