O’Melveny Worldwide

Jim counsels broker-dealers, exchanges, clearing agencies, alternative trading systems (ATSs), and private fund clients, as well as other SEC registered entities and their boards, on regulatory, compliance, and enforcement matters.

He is renowned for extensive government and private practice experience in both the trading and markets and investment management areas. He advises on SEC rulemaking matters and in examination and enforcement contexts, with a focus on strategic assistance on initiatives for registrants overseen by the SEC’s Division of Trading and Markets and the Division of Investment Management, FINRA, self-regulatory organizations, and other federal and state authorities. He has assisted numerous registrants navigating enforcement matters, ably counseling his clients and mitigating settlement outcomes in tough situations.

Jim offers unparalleled insights into how SEC rulemaking and other initiatives unfold, sensitive to how such matters affect the business operations and compliance programs of SEC registrants. He brings well-respected knowledge and understanding of the equity, listed options, fixed income, and derivatives markets. As Deputy Director of the SEC’s Division of Trading and Markets, Jim played an integral part in the development of key SEC positions affecting various instruments, markets, intermediaries, and sell- and buy-side participants. His SEC experience witnessed innovations to trading rules, registration requirements for domestic and international entities, clearance and settlement issues, developments of significance to the emerging fintech, event contract, and crypto asset space, and the use of complex financial products. As Deputy Chief of Staff to SEC Chair Mary Schapiro, he served a central role in responding to the Flash Crash and overseeing the development and execution of significant initiatives under the Dodd-Frank Act, including the Volcker Rule and the SEC’s security-based swap regulatory regime.

Jim also has wide-ranging SEC and private practice experience across broad areas of the asset management industry, covering investment managers and fiduciaries for private funds and other investment managers. He has extensive experience advising boards on governance, risk, compliance, and disclosure-related matters. He also brings his regulatory and smart business acumen to issues arising in complex financial services M&A transactions and in preparing new entities for the rigors of regulation.

Consistently selected for inclusion by Chambers USA for the past six years, Jim has been described as “outstanding” and “an excellent regulatory lawyer” and someone with “extensive knowledge” who “consistently hits the mark” in delivering for his clients, who have referred to him as “savvy” about a cross section of regulatory stakeholders and as particularly helpful when it comes to novel issues.

Jim has been noted by The Legal 500 for being highly skilled at managing complex financial services rulemaking responses and balancing diverse industry perspectives under tight deadlines. He is noted for maintaining important relationships with senior SEC and FINRA regulators, his deep knowledge, collaborative nature, and strong understanding of the regulatory process. 

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  • Numerous broker-dealers, exchanges, ATSs, clearing agencies, and asset managers in connection with regulatory reviews and enforcement actions overseen by the SEC and FINRA
  • Leading trade associations on preparing comment letters on key SEC rulemaking initiatives affecting broker-dealers, asset managers, and other registrants
  • Compliance program redesigns for numerous registrants
  • Diligence in connection with M&A activity relating to various registrants
  • Cross-border application of SEC registration and regulatory requirements
  • Crisis management for senior management and boards in connection with internal investigations, regulatory reviews, and enforcement settlements

Admissions

Bar Admissions

  • District of Columbia
  • Maryland

Court Admissions

  • U.S. Court of Appeals, Fourth Circuit

Education

  • Georgetown University Law Center, J.D., 2001
  • University of Oxford, D.Phil., 1997
  • University of Oxford, M.Phil., 1994
  • Harvard College, A.B., 1991

Honors & Awards

  • Ranked by Chambers USA in Financial Services Regulation: Broker Dealer (Compliance) (2021-2025)
  • Recognized by The Securities and Exchange Commission with Chairman’s Award of Excellence (Consolidated Audit Trail); Law and Policy Award (The Volcker Rule)

Professional Activities

Outside Counsel

  • National Organization of Investment Professionals