Partner
and access,
Tiffany Smith has over a decade of experience advising and representing broker-dealers and other financial institutions, including financial technology companies, regarding compliance with the federal securities laws and regulations and the rules of the self-regulatory organizations. Ms. Smith’s practice primarily focuses on four areas: (i) broker-dealer regulatory compliance, (ii) cryptocurrency regulatory compliance, (iii) representing clients in connection with enforcement matters and regulatory examinations, and (iv) providing regulatory advice in connection with corporate transactions. With respect to broker-dealer regulatory compliance, Ms. Smith often advises clients on newly adopted rules and areas of increased regulatory focus, including the rules on market access, securities trading and market activities, short sales, and issuer repurchases. Ms. Smith also has experience advising clients on the regulatory implications of new and emerging technologies (e.g., blockchain) and helping clients navigate the regulatory hurdles associated with these technologies. In addition, she counsels clients on triggers for broker-dealer registration, including those related to offshore activities and those related to the activities of financial technology companies. Finally, Ms. Smith has helped clients comment on proposed Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) rules, and represented clients seeking relief from adopted rules through the SEC and FINRA exemptive relief processes and the SEC no-action process. With respect to cryptocurrency regulatory compliance, Ms. Smith regularly advises cryptocurrency market participants including exchanges, custodians, NFT issuers and platforms, and technology providers. She has experience advising firms on the applicability of regulations to products, developing compliance programs and procedures, and advising clients through licensing processes including with state and federal banking regulators and the SEC. Ms. Smith has experience representing clients in connection with regulatory examinations, SEC, FINRA and state enforcement matters and inquiries, and the FINRA MC-400 Membership Continuance Process; and conducting internal investigations. Ms. Smith often serves as regulatory counsel in connection with corporate transactions involving broker-dealers, performs due diligence in connection with investments in cryptocurrency firms and NFT platforms, advises clients through the FINRA new and continuing member application processes, and counsels clients on the triggers for filing a FINRA continuing member application. At the firm, Ms. Smith has been active on the Diversity Committee, Hiring Committee, Pro Bono and Community Service Committee, and various volunteer-based initiatives. From 2016–2019, she was co-chair of firm's New York summer associate program.