FacultyFaculty/Author Profile
Chris Salter

Chris Salter

Allen & Overy

Washington, DC, USA


Chris Salter's practice focuses primarily on advising financial institution clients, and specifically broker-dealers, investment advisers, private equity funds, and hedge funds on compliance with the federal securities laws and regulations and on compliance with the rules of the self-regulatory organizations (SROs), including the Financial Industry Regulatory Authority.

Previously, Chris worked at the U.S. Securities and Exchange Commission (SEC) as an Attorney in the Division of Market Regulation. Chris also is a Certified Public Accountant who worked as an Audit Manager for the U.S. Government Accountability Office and as a Staff Accountant for KPMG Peat Marwick, where he obtained extensive accounting and financial regulatory experience.

While at the SEC, Chris responded to requests from broker-dealers and self-regulatory organizations for interpretation, guidance, and no-action relief with regard to the SEC's broker-dealer financial responsibility rules, including the net capital rule, the customer protection rule, the books and records rules and the financial reporting rules. In addition, Chris worked extensively on various SEC rulemaking efforts, including the adoption of a limited regulatory structure for dealers active in the over-the-counter derivatives market.

Chris has extensive experience advising clients with respect to broker-dealer and investment adviser regulation. He routinely helps broker-dealers and investment advisers in registering with the SEC, the states and becoming members of SROs. Chris routinely advises clients on their supervisory procedures and compliance policies, and assists clients with the development of their policies and procedures. Chris has extensive experience with compliance reviews and audits as well as internal investigations. Chris also represents clients in enforcement actions before the SEC, SROs, the U.S. Attorney's Offices, and the State Attorney General's Offices.

Experience highlights include advising:
  
  • A bidder on the sale by auction of Hartford Financial Services' broker-dealer subsidiary, Woodbury Financial Services, ultimately acquired by SunAmerica Financial Group, a subsidiary of AIG.
  •   A leading global alternative investment manager on ongoing regulatory issues related to compliance with the Advisers Act, including custody issues, marketing fund interests, conducting annual compliance reviews, conflicts of interest, and reviewing private placement memoranda and other offering documents to ensure appropriate disclosure information is included. We also advised on preparing the Form PF, which includes detailed information on private funds advised by the investment adviser. Among other things, Form PF requires disclosure of the types and amounts of investments made by the funds, the funds' assets and borrowings, the funds' ownership structure, and performance information.
  •   A major international financial services company on conducting an internal investigation of its U.S.-based brokerage firms' compliance with record retention requirements, and reviewing its supervisory structure and internal controls governing compliance with those requirements. The SEC and FINRA require registered broker-dealers to make and retain certain records relating to their securities business. Following identification of multiple record retention problems, we were asked to assist our client in investigating its record retention problems and in developing and implementing new internal controls and supervisory procedures. The client self-reported the problems and we are now representing the client with respect to a FINRA investigation.
  •   A specialized commercial finance company in connection with its joint venture with a U.S.-based financial institution to determine whether the proposed activities to be conducted required registration under the Advisers Act; on the structure and operations of the joint venture to determine whether a different approach would impact the analysis of whether registration under the Advisers Act was required; and ultimately, on registering as an investment adviser under the Advisers Act.
  •   A U.S. investment adviser on the regulatory and compliance issues in connection with business expansions and the acquisition of additional asset management businesses. We also provide ongoing regulatory advice and counseling related to compliance with the Advisers Act.
  •   A mezzanine fund, a leading global alternative investment manager, a UK-based adviser to private funds, and a distressed debt fund that invests solely in investments based in China on registering as investment advisers under the Investment Advisers Act of 1940 (Advisers Act), to include preparing Part 1 of the Form ADV, the brochure and brochure supplement; and drafting and developing written supervisory procedures reasonably designed to prevent violations of the Advisers Act and a code of ethics. 

 

 Career History
  Partner, Allen & Overy LLP, Washington, D.C., 2011
  Partner, O'Melveny & Myers LLP, Washington, D.C., 2005-2011
  Fried, Frank, Harris, Shriver & Jacobson LLP, 1999-2005
  United States Securities and Exchange Commission, 1996-1999
  United States Government Accountability Office, 1990-1996
  KPMG, 1989-1990 

 Legal Qualifications
  Admitted to the Bar, District of Columbia, 2000
  Admitted to the Bar, State of Virginia, 1995 
 
Academic Qualifications
  J.D., George Mason University School of Law, 1995
  B.B.A, cum laude, James Madison University, 1989

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