Amy Greer serves as the co-chair of Baker McKenzie's North America Financial Regulation & Enforcement Practice, which provides clients with a full range of regulatory advice and enforcement counseling. Amy also serves on the steering committees of the Firm's Global Financial Services Regulatory and Global Financial Institutions Groups.
Previously, Amy served as chief trial counsel at the US Securities and Exchange Commission's (SEC) Philadelphia regional office and managed a team of lawyers overseeing a wide variety of enforcement matters.
Amy advises all manner of financial industry clients and SEC reporting companies, in connection with regulatory enforcement investigations and examinations, as well as internal investigations. Her clients include broker-dealers, investment advisers, hedge funds, mutual funds, securities issuers and reporting companies, commodities traders, and those providing services to those businesses.
Drawing on her experience leading an SEC regional office trial program, Amy provides practical and forward-looking guidance to clients, who seek her advice on matters as diverse as conflict of interest disclosures, sales practices concerns, insider trading/market abuse, financial reporting and accounting issues, securities offerings, investigations into complex products and trading, and whistleblower concerns.
Amy is known for her ability to narrow the focus of an inquiry, get to the heart of an issue with precision, and efficiently manage complex matters. She often coordinates her efforts on behalf of our clients with ongoing criminal investigations, among multiple enforcement/regulatory activities, and with civil litigation, or with such potential proceedings in mind.
Representative Legal Matters
- Represented multiple investment advisers and dually registered investment adviser-broker dealer firms in connection with the SEC's share class selection disclosure (SCSD) self-reporting initiative. The SCSD initiative targeted the adequacy of disclosures by financial services firms of conflicts of interest when recommending mutual fund share classes that pay distribution fees (12b-1 fees) to the firms or their affiliates, when lower cost share classes are available.
- Represented a multinational brokerage and financial services company in connection with an industry-wide SEC investigation into "pre-released" American Depositary Receipts (ADRs) and successfully negotiated a favorable settlement.
- After successfully convincing FINRA not to proceed against her high-frequency, algorithmic market maker client, Amy steered that same client through negotiations with the SEC toward a successful resolution of claims that it had failed to fully disclose how it was executing trades for its broker-dealer clients.
Prior to joining the Firm, Amy handled the following matters:
- Successfully persuaded the SEC Staff to close investigation of a high-yield bond fund, its portfolio manager, bond trader, and chief compliance officer, in connection with Staff's review of pricing of trades in illiquid securities.
- Represented several affiliated broker-dealer firms in connection with FINRA's investigation of sales practices and customer disclosures related to variable annuity products. We were able to obtain a favorable settlement for these clients, at a critical time in their businesses.
- Convinced SEC Enforcement to close its investigation of a global financial services client, which had been opened based on allegations by a putative whistleblower, asserting a variety of claimed securities laws violations.
- After multiple referrals of examination findings were consolidated, successfully resolved SEC Enforcement matter charging multiple compliance failures and breaches of fiduciary duty by affiliated dual registrant firms.
- Represented a global financial services firm in connection with an SEC investigation into the firm's market making activities related to the initial listing of securities that tracked certain cryptocurrencies, resulting in a successful settlement.
- Represented a large financial services firm in connection with an SEC investigation into trading in advance of the initiation of research coverage; the matter was closed with no action.
- Defended a major global financial institution in an SEC investigation into mortgage securitization and marketing practices and related financial reporting issues.
- Recognized, SEC Chairman's Award for Excellence, 2007
- Partnership Award, Allegheny County Bar Foundation, 2005
- Emissary for Justice Award, Pennsylvania Legal Services, 2003
- Outstanding Service Recognition, Neighborhood Legal Services Association, 1995
- Pro Bono Program Outstanding Volunteer, Allegheny County Bar Association, 1995
- Pro Bono Publico Award, American Bar Association, 1995
Professional Associations and Memberships
- New York City Bar Association - Member
- DC Bar Association - Member
- Allegheny County Bar Association (Pittsburgh) - Member and Former President
- Bedlam Theatre - Member, Board of Directors
- District of Columbia (2017)
- New York (2009)
- Pennsylvania (1989)
- U.S. Court of Appeals, Second Circuit (2012)
- U.S. Court of Appeals, Third Circuit (1990)
- U.S. Court of Appeals, Fourth Circuit (1990)
- U.S. District Court, Southern District of New York~United States (2011)
- U.S. District Court, Eastern District of Pennsylvania~United States (2005)
- U.S. District Court, Western District of Pennsylvania~United States (1989)
- Marshall-Wythe School of Law of the College of William and Mary (JD) (1989)
- Gettysburg College (BA) (1985)
- Co-author, "Is the Third Time the Charm? How the Proposed DOL Fiduciary Rule Intersects with Regulation Best Interest," Baker McKenzie, July 2020
- Co-author, "Bite-size Briefings: Conflicts of interest and spread charges - a continuing focus for global regulators," Baker McKenzie, July 2020
- Co-author, "SEC enforcement and COVID-19 - How Lessons from the financial crisis apply today," Baker McKenzie, June 2019
- Co-author, "Securities claims and government investigations relating to COVID-19 - D&O coverage considerations," Baker McKenzie, April 2020
- Co-author, "A Closer Look at Regulation Best Interest Implementation Developments," Baker McKenzie, April 2020