Washington, D.C.
Ignacio engages with the SEC and the Financial Industry Regulatory Authority (FINRA) on behalf of clients on critical matters related to their business by seeking regulatory relief, interpretive guidance, exemptions and as a subject matter expert in enforcement and examination matters. He advises major U.S. broker-dealers in their clearing, retail, trading and institutional businesses, and on their financial responsibility and operational obligations.
Ignacio has counseled numerous broker-dealers on their obligations under the net capital rule (Rule 15c3-1), the customer protection rule (Rule 15c3-3), margin (Regulation T, Regulation U, Regulation X, FINRA Rule 4210, etc.), recordkeeping and reporting rules (Rule 17a-3, Rule 17a-4, Rule 17a-5, Rule 17a-8, Rule 17a-11, Rule 17a-13, etc.) and other middle office and back-office requirements. He has drafted market standard clearing and custody agreements for broker-dealers and has experience working on various types of agreements affecting market intermediaries and participants, including trading agreements, customer agreements, distribution agreements and platform agreements.
Ignacio regularly registers and provides support to alternative trading systems (ATS) and counsels market participants regarding their obligations to register as such. In addition, he has helped broker-dealers develop management platforms for clients involving money market funds and other cash equivalent instruments. He also has experience with cash sweep programs involving money market funds and bank deposit programs insured by the Federal Deposit Insurance Corporation (FDIC).
Ignacio’s experience also includes matters relating to domestic and foreign broker-dealer registrations, customer account statement and confirmation requirements, mergers and acquisition brokers, anti-money laundering obligations for buy-side and sell-side participants, transaction confirmations and outsourcing broker-dealer technology and platforms. He counsels foreign exchanges and foreign clearing organizations regarding U.S. regulatory obligations on the access of U.S. person to foreign options markets and security-futures products.