Neal Sullivan is co-chair of Bingham's Financial Services Area, a 300-lawyer group within the firm, practice group leader of the firm's Broker-Dealer Group and co-managing partner of the Washington office. He conducts a comprehensive securities regulatory practice and maintains a particular focus on broker-dealer and investment adviser matters. Neal regularly represents clients before the SEC, FINRA, and other self-regulatory organizations and state securities agencies, frequently concerning emerging regulatory issues. In addition, he has extensive experience with private and public investigations and enforcement proceedings brought by the SEC, FINRA, and its predecessor entities (NASD and NYSE) and state agencies.
A dynamic and effective enforcement counsel, Neal is also one of the leading advisors to the securities industry on major compliance and regulatory matters. He has played a central role in several significant projects such as representing Morgan Stanley in obtaining regulatory approvals for the 2009 launch of Morgan Stanley Smith Barney, the country's largest retail broker-dealer; the 2007-2008 sale of Boston Options Exchange from NASDAQ and the Boston Stock Exchange to the Montreal Stock Exchange/Toronto Stock Exchange; and in its subsequent Form 1 filing with the SEC to become a national self-regulatory organization.
He has represented clients in all of the SEC's major Wall Street investigations, including the sale of auction-rate securities, other structured products and various subprime mortgage-related matters; mutual fund market timing; and research analyst conflicts of interest. 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.
Neal serves as outside counsel to the Boston Options Exchange and to Bourse de Montréal with regard to U.S. registration issues. He was formerly outside counsel to the Boston Stock Exchange, and helped create the market structure and marketplace for the Boston Options Exchange, an all-electronic equity derivatives market launched in 2004.
He is the former executive director of the North American Securities Administrators Association. During his tenure 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 is also a former vice president of regulation at the Boston Stock Exchange. Prior to his tenure at the Boston Stock Exchange, Neal was the chief of the Massachusetts Securities Division.
Neal appears regularly on industry and legal panels that address issues of concern to the securities industry. He has co-chaired the Fall PLI course on broker-dealer regulation in New York City annually since 2007. Neal was an invited speaker at the first and second annual NYSE Regulation Securities conferences. He also speaks at FINRA's fall and spring annual conferences, as well as the SIFMA annual meeting and certain SIFMA regional meetings. 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 has authored several published articles on regulation of broker-dealers.
Admitted to practice in the District of Columbia and Massachusetts
Registered Foreign Lawyer in England and Wales
Suffolk University Law School, Juris Doctor, 1990
Stonehill College, Bachelor of Arts, 1982