FacultyFaculty/Author Profile
Neal E. Sullivan

Neal E. Sullivan

Sidley Austin LLP

Washington, DC, USA


NEAL SULLIVAN, a member of the Firm’s Executive Committee, is co-leader of Sidley’s Securities & Derivatives Enforcement and Regulatory practice, which received the 2016 Chambers USA Award for “Financial Services and Securities Regulation.” Neal conducts a comprehensive securities regulatory and enforcement practice in which he represents broker-dealers, investment banks, investment advisers, accounting firms, public companies, and senior corporate officers before the SEC, DOJ, DOT/FinCEN, PCAOB, FINRA, state attorneys general and securities regulators in private and public investigations and enforcement proceedings and in connection with international securities regulatory matters. 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 financial services clients in many of the SEC’s major Wall Street investigations in the past 15 years, including anti-money laundering, insider trading, the sale of auction-rate securities, other structured products and various subprime mortgage-related matters; mutual fund market timing. He 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.

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 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 has co-chaired the Fall PLI course on broker-dealer regulation annually since 2007. 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 has authored several published articles on regulation of broker-dealers.

Neal E. Sullivan is associated with the following items:
Web Segment  Web Segment Broker/Dealer: State Enforcement Initiatives, Developments and Priorities - Broker/Dealer Regulation and Enforcement 2017, Tuesday, October 17, 2017
Course Handbooks  Course Handbooks Broker/Dealer Regulation and Enforcement 2017
CHB Chapters  CHB Chapters NASAA Broker-Dealer Section Study of Senior Practices and Procedures, 2016–2017 - Broker/Dealer Regulation and Enforcement 2017, Tuesday, October 17, 2017
Memorandum of Understanding Regarding the Treatment of Non-Public Information Shared Between the North American Securities Administrators Association and the Securities and Exchange Commission (February 17, 2017) - Broker/Dealer Regulation and Enforcement 2017, Tuesday, October 17, 2017
Outline: State BD Regulation & Enforcement - Broker/Dealer Regulation and Enforcement 2017, Tuesday, October 17, 2017
MP3 Audio  MP3 Audio Broker/Dealer: State Enforcement Initiatives, Developments and Priorities - Broker/Dealer: State Enforcement Initiatives, Developments and Priorities, Tuesday, October 17, 2017
MP4 - Mobile Video Seg  MP4 - Mobile Video Seg Broker/Dealer: State Enforcement Initiatives, Developments and Priorities - Broker/Dealer: State Enforcement Initiatives, Developments and Priorities, Tuesday, October 17, 2017
On-Demand Web Programs  On-Demand Web Programs Broker/Dealer Regulation and Enforcement 2017, Wednesday, October 18, 2017, New York, NY
Live Seminar  Live Seminar Broker/Dealer Regulation and Enforcement 2018, Tuesday, October 16, 2018, New York, NY
Live Webcast  Live Webcast Broker/Dealer Regulation and Enforcement 2018, Tuesday, October 16, 2018, New York, NY
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