Barbara Stettner

Partner

Barbara Stettner is a partner in O’Melveny's Washington, DC office and a member of the Securities Enforcement and Regulatory Counseling Practice. Barb’s practice focuses on advising U.S. and foreign financial institutions on their regulatory and compliance obligations under the Securities Exchange Act of 1934 and the Investment Advisers Act of 1940.

Before entering private practice, Ms. Stettner worked in the SEC's Division of Market Regulation, where she served as Special Counsel in the Office of the Chief Counsel and as an Attorney-Advisor in the Office of Risk Management and Control. She also served as Senior Counsel in the Commission's Office of International Affairs. Prior to joining the firm, Ms. Stettner practiced at a prominent law firm in Washington, DC.

Illustrative Professional Experience

• Counsel foreign and domestic broker dealers, banks, securities exchanges, electronic communications networks, third-party research providers, and investment advisers on various aspects of securities regulations
  
• Counsel multinational banks and their broker dealer affiliates on the push-out provisions of the Gramm-Leach-Bliley Act
  
• Counsel broker dealers, private equity funds and investment advisers on their respective obligations under the PATRIOT Act
  
• Advise foreign exchanges, foreign banks and US broker dealers on foreign market access issues and the application of rule 15a-6
  
• Review broker dealers’ compliance with the financial responsibility rules (net capital, customer protection) under the Exchange Act and NASD and NYSE rules
  
• Prepare written supervisory procedures for broker dealers, with recent emphasis on compliance with analyst conflicts disclosure, IPO allocations, anti-money laundering, advertising, and privacy laws
  
• Advise broker dealers on issues involving the sponsorship, distribution, marketing and sales of mutual funds and other investment companies and section 529 College Savings Plans
  
• Evaluate Internet-based companies for broker dealer or investment adviser status under the Exchange Act and Investment Advisers Act

Professional Activities

Member, American Bar Association
Author, "Campaign Contributions: Benevolent Civic Participation or Danger Zone for Investment Advisers to Private Funds?," The Investment Lawyer (February 2007), with Bill Satchell, Adam Hellman, and Astri Kimball; "The Distribution of Private Fund Securities: Regulatory Considerations and Potential Liabilities When Using Unlicensed Finders," The Investment Lawyer (September 2005), with Darren Vieira; "Proposed Anti-Money Laundering Program Requirements for Unregistered Investment Companies and Unregistered Investment Advisers," O'Melveny & Myers Client Alert (September 2003); "New Customer Identification Requirements for Broker-Dealers," O'Melveny & Myers Client Alert (May 2003); "The New Anti-Money Laundering Responsibilities of Broker-Dealers," Insights, The Corporate & Securities Law Advisor (July 2002)