Amy Natterson Kroll counsels US and non-US financial institutions on US regulatory requirements and best practices related to broker and dealer activities. Clients seek Amy’s advice on, among other things, issues related to implementation of new regulations; the acquisition and sale of broker-dealers; expansion of business and related regulatory requirements for financial institutions; and regulations related to the capital markets, such as research activities and research analysts, supervisory controls and internal controls, and cross-border securities activities. Amy also advises clients on the collateral consequences of enforcement, civil, and criminal actions. She has a specific interest in the issues central to regional full-service and mid-market broker-dealers.
Amy worked at the Securities and Exchange Commission twice. From 1997–1998 she was assistant general counsel (legislative and financial services) at the SEC, to which she had returned after five years in private practice counseling broker-dealers and other financial institutions. From 1984–1991, during her first tour of SEC service, she served in positions of increasing responsibility, first as an attorney-adviser in the division of Market Regulation (now the division of Trading & Markets), and subsequently as counsel to Commissioner Edward H. Fleischman and as senior special counsel in the division of Corporation Finance, Office of International Corporate Finance.
From 1998–2003, Amy was an independent consultant, focusing on issues confronted by non-US financial entities seeking to engage in broker-dealer activities in the United States. During that time, she also taught at the Washington College of Law, American University.
Amy serves as the Washington office practice group leader for the firm’s investment management practice and also is the Washington office hiring partner. She previously served as a member of the NASDAQ Market Operations Committee. Prior to joining Morgan Lewis, Amy was a partner in the financial institutions regulatory, enforcement, and litigation practice at another international law firm.
Member, Practice Group of the Year, Asset Management, Law360 (2017)
Ranked, Financial Services Regulation: Broker Dealer (Compliance), Nationwide, Chambers USA (2017, 2018)
Vice-Chair, National Capital Poison Center, an independent, nonprofit organization that provides poison control services to residents of Washington, DC, and its surrounding counties
11/3/2017 - SEC Tackles MiFID II Research Issues
6/23/2017 - Nevada Imposes Fiduciary Obligations on Broker-Dealers and Investment Advisers
5/12/2017 - Shaping FINRA's Desk Commentary Safe Harbor, Law360
4/20/2017 - FINRA Proposes Limited Relief for Desk Commentary
2/13/2017 - FINRA Rule: Thou Shalt Not Exploit Thine Elders
9/13/2016 - FINRA’s Proposed Rules on Gifts, Gratuities, and Non-Cash Compensation
5/10/2016 - Crowdfunding Begins on May 16, 2016
2015-2016 - Hedge Fund Deskbook
October 2015 - SEC Approves Rule to Regulate Debt Research Reports and Debt Research Analysts
7/22/2015 - SEC Approves Long-Anticipated FINRA Research Rules
2/24/2015 - FINRA Issues Guidance on Materiality Consultations
2/12/2015 - SEC and FINRA Publish Materials Addressing Cybersecurity
February 2015 - Select Broker-Dealer Enforcement Cases and Developments: 2014 Year in Review
4/9/2014 - FINRA Initiates Retrospective Rule Review Heavy on Process, Vague on End Game
3/28/2014 - FINRA Announces Effective Date for Consolidated Supervision Rules
2/26/2014 - Final Volcker Rule Regulations: Effects on Non-U.S. Entities
2/10/2014 - SEC Issues No-Action Letter Regarding Broker-Dealer Registration Status of M&A Brokers
1/23/2014 - Volcker Rule: Compliance Program, Reporting, and Recordkeeping Requirements
1/17/2014 - Regulators Issue Annual Priorities Letters for Broker-Dealers
1/9/2014 - Final Volcker Rule Regulations: Restrictions on Proprietary Trading
12/11/2013 - Regulators Adopt Final Volcker Rule Regulations
11/25/2013 - 2013 Recommended Annual Review for Hedge Fund and Other Private Fund Advisers
9/18/2013 - FINRA Files With SEC to Amend Rule on "Spinning" New Issues
9/11/2013 - SEC Issues Guidance on Investment Advisers’ Business Continuity Plans
7/1/2013 - FINRA Submits to SEC Consolidated Supervision Rule
5/6/2013 - SEC Issues Proposed Rules on Cross-Border Security-Based Swap Activities
4/8/2013 - SEC Trading and Markets Chief Counsel Comments on Private Fund Sales and Marketing
3/25/2013 - SEC Staff Issues Long Awaited Rule 15a-6 FAQs
3/12/2013 - SEC Requests Input for a Potential Uniform Fiduciary Standard of Conduct
12/17/2012 - FINRA Issues Guidance Narrowing the Scope of its New Suitability Rule
10/16/2012 - FINRA Responds to Comments: Re-proposes Debt Research Rule
9/4/2012 - JOBS Act Research Analyst Communications FAQs
4/2/2012 - JOBS Act: Congress Attempts to Reduce Regulatory Burdens on IPOs and Private Offerings
2/24/2012 - FINRA Proposes Debt Research Rule: FINRA Regulatory Notice 12-09
2/7/2012 - FINRA Annual Priorities Letter
10/10/2011 - SEC Targets Master/Sub-Account Trading Model for Examination
9/26/2011 - MSRB Publishes Notice on Applicability of its Rules to Bank Loans
9/12/2011 - MSRB Withdraws Proposed Municipal Advisor Rules Previously Filed With the SEC
9/6/2011 - MSRB Forges Ahead With Municipal Advisor Rule Proposal Filings With the SEC
8/3/2011 - SEC Publishes FINRA Proposal for Complete Rewrite of Communications With the Public Rules
3/17/2011 - FINRA Issues Long-Awaited Concept Proposal for Regulation of Debt Research
12/10/2010 - FINRA Rule 5131 Regarding Allocations Practices for New Issues Approved by SEC
10/12/2010 - Summary of the Dodd-Frank Wall Street Reform and Consumer Protection Act
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