SEC Amends Regulation NMS to Provide for Half-Penny Quoting in Securities and Reduction in Potential Rebate Money
10 minute read | September.24.2024
Ignacio Sandoval
Partner
Washington, D.C.
Ignacio A. Sandoval is a securities and financial institutions lawyer who helps clients meet their business objectives consistent with regulatory obligations. Drawing on experience as a special counsel in the Office of Chief Counsel in the U.S. Securities and Exchange Commission (SEC) Division of Trading and Markets, Ignacio counsels broker-dealers, securities exchanges, alternative trading systems, transfer agents, clearing organizations, banks and other domestic and foreign market participants in traditional and emerging industries, such as digital assets and the use of artificial intelligence.
Ignacio engages with the SEC and the Financial Industry Regulatory Authority (FINRA) on behalf of clients on critical matters related to their business by seeking regulatory relief, interpretive guidance, exemptions and as a subject matter expert in enforcement and examination matters. He advises major U.S. broker-dealers in their clearing, retail, trading and institutional businesses, and on their financial responsibility and operational obligations.
Ignacio has counseled numerous broker-dealers on their obligations under the net capital rule (Rule 15c3-1), the customer protection rule (Rule 15c3-3), margin (Regulation T, Regulation U, Regulation X, FINRA Rule 4210, etc.), recordkeeping and reporting rules (Rule 17a-3, Rule 17a-4, Rule 17a-5, Rule 17a-8, Rule 17a-11, Rule 17a-13, etc.) and other middle office and back-office requirements. He has drafted market standard clearing and custody agreements for broker-dealers and has experience working on various types of agreements affecting market intermediaries and participants, including trading agreements, customer agreements, distribution agreements and platform agreements.
Ignacio regularly registers and provides support to alternative trading systems (ATS) and counsels market participants regarding their obligations to register as such. In addition, he has helped broker-dealers develop management platforms for clients involving money market funds and other cash equivalent instruments. He also has experience with cash sweep programs involving money market funds and bank deposit programs insured by the Federal Deposit Insurance Corporation (FDIC).
Ignacio’s experience also includes matters relating to domestic and foreign broker-dealer registrations, customer account statement and confirmation requirements, mergers and acquisition brokers, anti-money laundering obligations for buy-side and sell-side participants, transaction confirmations and outsourcing broker-dealer technology and platforms. He counsels foreign exchanges and foreign clearing organizations regarding U.S. regulatory obligations on the access of U.S. person to foreign options markets and security-futures products.
-
- Represented various non-U.S. securities exchanges in preparing notification letters to and meetings conditions of SEC relief for U.S. facing activities.
- Assisted a broker-dealer in its implementation of a digital asset lending messaging platform.
- Registered an alternative trading system on behalf of a broker-dealer for in its internal agency cross trades.
- Counseled a leading money market fund cash management platform on regulatory changes and operational implementations.
- Drafted three comment letters on SEC’s dealer rule.
- Represented various broker-dealers in connection with application of SEC Staff Accounting Bulletin no. 121 to their digital assets business.
- Counseled major broker-dealer on implementation of new electronic recordkeeping framework.
- Redrafted clearing agreements for major U.S. broker-dealers.
- Counseled money manager in its implementation of T+1 rules and new recordkeeping requirements applicable to investment advisers.
