Brian O’Neill’s practice focuses on broker-dealer and exchange regulatory compliance issues and advising companies on matters related to compliance with SEC and self-regulatory organization (SRO) regulations. Brian counsels clients on a wide range of legal, regulatory and compliance matters, including equity and options trading rules, listing of new equity and options products, options linkage, policies and procedures for trading systems development and testing, sales practices, short sales, Regulation NMS, Regulation SCI, Form 1 exchange registration and amendments, Regulation ATS, market-making, investment adviser regulation, SRO investigations, and development of compliance and testing programs. He also advises clients on equities and derivatives market structure initiatives, including market access, market data, new products, transaction fees, and SEC policy initiatives.
Brian counsels broker-dealers, exchanges, alternative trading systems, clearinghouses and firms with market-making, proprietary trading and algorithmic models. He also represents banks, asset managers and broker-dealers on regulatory requirements involving municipal advisors, investment advisers, and securities-based swap dealers. In addition, he conducts independent compliance and technology reviews and audits related to enforcement action settlements.
Brian spent most of his legal career at regulators and SROs, including time at the SEC, FINRA, CFTC, NYSE Euronext, MIAX Options Exchange, and the state regulator DISB. Over the course of his regulatory career, Brian has reviewed and/or drafted over 500 rules and corresponding 19b-4 rule filings for equity and options exchanges. He managed the legal department of an exchange and served as lead regulatory counsel where he designed and drafted a Form 1 exchange registration for a new equities exchange, and drafted comment letters, policies and procedures, and responses to regulatory inquiries. In addition, Brian participated on industry-wide committees where he drafted model rules used by exchanges.
Prior to joining Bradley, Brian served as an executive director and compliance director at a large financial institution where he managed an international team with responsibilities in APAC, EMEA, LATAM and North America. He created and managed a compliance program for investment management and wealth management groups, developed policies and procedures, and designed risk controls to monitor and test the effectiveness of the new compliance program.
Brian is a former member of the Chicago Board of Trade, where he traded futures as a floor trader. He was also a Sergeant in the United States Marine Corps, where he served as a heavy machine-gunner and Embassy Guard in Switzerland and Bangladesh.*Admitted only in Maryland; practicing law in the District of Columbia pending admission to the D.C. Bar and under the supervision of principals of the firm who are members of the D.C. Bar.