Thomas J. Hennessey

During his career, Thom has focused his practice on regulatory and internal investigations concerning retail wealth management operations and products. Thom has defended clients in investigations directed at complex retail products including structured, market-linked, and alternative investments, as well as conventional offerings such as mutual funds, exchange-traded funds (ETFs), and cash management products. His ongoing representations cover cutting edge retail wealth management issues including dual- and multi-share class products, ETF clones, alternative investments, the use of private investments in retirement accounts and a variety of matters involving product fee transparency. Thom’s matters frequently include complex assessments and analyses of product use across wide retail investor populations through partnership with internal client experts and external consultants when needed.

Thom is a seasoned trial lawyer. He has conducted jury and bench trials in state and federal court, before arbitral forums including FINRA and the ICC, and in regulatory administrative venues. While maintaining a consistent recognition of clients’ regulatory relation priorities, Thom has extensive experience with aggressive enforcement efforts that require equally active defense. Thom’s matters frequently involve the coordinated management of regulatory inquiries, parallel civil customer claims including class actions, and, in some cases, law enforcement inquiries.

Operating from the firm’s Boston office, Thom has a strong background in state securities enforcement matters and administrative proceedings, frequently those involving the country’s most active and aggressive state agencies. Thom has experience in coordinated state actions managed through consortiums of lead state regulators and/or the North American Securities Administrators Association (NASAA), which require careful management. Thom has defended clients in state administrative adjudicatory venues and, when unavoidable, managed judicial challenges to the scope of state regulatory authority and federal preemption.