Evan Rosser is an experienced and respected securities industry professional with 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 CCO support to several additional firms. Evan has also served as both a SEC-approved and a FINRA-approved independent consultant. Evan’s recent broker-dealer engagements have focused on market issues such 15c3-5 compliance, Reg SHO, and order type behavior. 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 corporate financing and advertising rule violations.

Expertise

  • 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 that occurred in 2012
  • Provides comprehensive guidance and assistance to clients preparing to comply with the Department of Labor Fiduciary Rule.  This includes: review and assessment of current retirement accounts; assessment of potential impact on client’s retirement business, including but not limited to compensation structure, need to rely upon Best Interest Contract Exemption, revisions to compliance and supervisory policies and procedures, product offerings, and technology platform; best practice recommendations; and the implementation process
  • FINRA-approved independent consultant hired to conduct a 15c3-5, 17a-3, Regulation SHO audit related to the Firm’s $10M settlement in 2013
  • Served as Chief Compliance Officer for 3 Registered Investment Advisors and a broker-dealer
  • Performed FINRA Rule 3120 Reviews, AML audits, broker-dealer process and procedures reviews, and investment advisor mock exams

Career Highlights

  • 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 FINRA, SEC, and SIFMA conferences and securities industry gatherings around the country
  • 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

Education, Accolades and Industry Commitments

  • B.A., Bucknell University
  • Series 7, 24, and 63 registrations (Registrations are typically inactive, but may be used when appropriate to perform interim functions for our clients)
  • Member of the National Society of Compliance Professionals (NSCP), SIFMA’s Financial Management Society, and the Association of Certified Anti-Money Laundering Specialists (ACAMS)
  • NASD President’s Award and NASD Excellence in Service

Articles, Blogs and Presentations

“FINRA expected to adopt CARDS despite local industry resistance” – Evan Rosser (quoted) – Investment News article

FINRA Folds Its CARDS Until Industry Concerns Addressed – Blog Post, May 26, 2015

SEC Releases Findings of Broker Dealers Involved in Sale of Securities of Microcap Companies – Blog Post, November 20, 2014