Dechert LLP

Broker-Dealers, Securities Trading and Markets

Partner

K. Susan Grafton counsels a wide variety of broker-dealers, including U.S. and multinational broker-dealers, full service firms, institutional and retail broker-dealers, equity and fixed income alternative trading systems, investment banking boutiques, and private placement agents as well as securities exchanges.

Ms. Grafton’s practice includes representing broker-dealers in all aspects of regulatory compliance, beginning with assisting them in registering with the SEC – as alternative trading systems as well as broker-dealers – and obtaining membership in the Financial Industry Regulatory Authority (FINRA) and other self-regulatory organizations (SROs). As part of this process, she drafts all needed documents, such as written supervisory procedures, customer account documents, soft dollars and commission sharing agreements, and electronic access agreements. She also advises clients on new business initiatives and assists them in obtaining required SRO and state approvals. Similarly, she handles the regulatory approvals in connection with changes of control of broker-dealers. Ms. Grafton also advises clients on broker-dealer status questions for themselves and their employees, including compliance with the Rule 15a-6 safe harbor for foreign broker-dealers and drafts agreements and procedures related to the same.

American Bar Association, Federal Securities Law Committee of the Section of Business Law Former Chair, Trading and Markets Subcommittee FINRA Corporate Financing Rules Subcommittee Hedge Funds Subcommittee The Association of Securities and Exchange Commission Alumni Board of Trustees, Securities and Exchange Commission Historical Society Securities Industry and Financial Markets Association, Legal and Compliance Division

McDaniel College, B.A., 1980 The Catholic University of America, Columbus School of Law, J.D., 1985 Georgetown University Law Center, LL.M., 1989