A successful engagement is when I can use my years of experience in the industry and as a regulator to help a client address a novel or new regulatory challenge.
Evan Rosser is an experienced and respected securities industry professional with over 25 years of experience managing complex securities investigations for NASD/FINRA and providing compliance expertise to both broker-dealers and investment advisors. As an Oyster consultant, Evan has served as CCO for both investment advisors and broker-dealers, as well as providing compliance support to numerous broker-dealers and registered investment advisors. Evan has also served as an independent consultant in both SEC and FINRA enforcement actions involving Rule 15c3-5 and Market Access, AML, market manipulation and low-prices securities trading. He has served as an expert witness in FINRA enforcement actions and arbitrations. Prior to consulting, Evan supervised FINRA Enforcement’s investigative staff of more than 40 supervisors and examiners, and successfully completed hundreds of investigations alleging numerous FINRA and SEC rule violations including NASDAQ and OTCBB trading violations, excessive equity markups, and NASD/FINRA sales practice, corporate financing and advertising rule violations.
- Providing expertise and guidance to numerous broker-dealers in complying with Reg BI and Form CRS
- Assisted with drafting of Form ATS and prepared Reg ATS compliance procedures as part of broker-dealer FINRA member application
- Worked with SEC–required Independent Consultant on policies and procedures for an ATS to remediate deficiencies in handling confidential trading information as required by Reg ATS 301(b)(10)
- Independent consultant hired to conduct a 15c3-5 review as part of a broker-dealer’s settlement with the SEC for a significant trading error
- FINRA independent consultant hired to conduct a 15c3-5, 17a-3, Regulation SHO audit related to the Firm’s $10M settlement
- FINRA Independent Consultant in two AML, low-priced securities enforcement actions
- Expert witness in both arbitrations and enforcement actions
- Conducted AML testing, OSJ and branch examinations, mock examinations, WSP review and drafting, and 3120 Reviews for numerous broker-dealers, and Annual Compliance Reviews, remediations, mock examinations, WSP review and drafting for both SEC and state regulated RIAs
- Served as Chief Compliance Officer for three registered investment advisors and four broker-dealers
- Frequent panelist and speaker at securities industry gatherings around the country on regulatory, compliance, and enforcement issues
- Vice-President and Director in FINRA’s Enforcement Department supervising industry “sweeps” and complex investigations
- Served as the first head of FINRA’s Criminal Prosecution Assistance Group, a group that lends regulatory, industry, and securities markets expertise to criminal prosecutors
- Represented NASD in implementing the provisions of the landmark 2003 Global Research Analyst Settlement which required firms to provide independent research to their customers. For this work, he received NASD’s President’s Award for Outstanding Performance.
- Frequent panelist and speaker at securities industry gatherings around the country and FINRA, SEC, and SIFMA conferences
- Provided training on securities fraud, U.S. equity markets, Nasdaq and OTC/Pink Sheet trading, NASD/FINRA rules to SEC examining staff, FBI agents and criminal prosecutors