Practice Areas - SEC Enforcement
- White Collar Criminal Defense
- Crisis Management
- Internal Corporate Investigations
- Foreign Corrupt Practices Act
| - Corporate Governance
- Regulatory Compliance
- Investment Funds
- Investment Banking and Broker-Dealer
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| Contact Info | Telephone: 214-651-5783 Fax: 214-200-0860 http://www.haynesboone.com/kit_addleman/
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| University | Wake Forest University, B.A., American/Comparative Politics, 1983 |
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| Law School | Oklahoma City University School of Law, J.D., with distinction, 1986 |
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| Admitted | 1986, Oklahoma; 1990, Texas and U.S. District Court, Northern District of Texas |
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| Special Agencies | Securities and Exchange Commission. |
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| Born | Philadelphia, Pennsylvania |
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| ISLN | 909537805 |
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| Transactions | Provided training and compliance guidance to Fortune 100 company including board of directors, senior management, and financial reporting teams surrounding the SEC's disclosure requirements related to financial reporting and management's discussion and analysis; Advised investment advisory firms and investment funds on SEC compliance issues; Revised compliance manuals, reviewed advisory agreements, investment management agreements, and third party contracts; Addressed procedures and books and records requirements including those applicable to the custody rules, pay-to-play restrictions, and other recent SEC actions; Counseled investment advisers and funds in preparation for compliance inspections and examinations and addressed SEC deficiency letters and concerns; Drafted and updated insider trading policies for public companies, including Fortune 500 and NYSE-listed companies, as well as investment funds and investment advisers; Provided advice to public companies, investment advisers, funds and individuals regarding trading decisions and compliance with insider trading restrictions; Defended portfolio manager in SEC investigation of money market fund; Defended sales representative in SEC investigation of oil and gas offering; Defended investment adviser in connection with cease-and-desist order from a state securities commission and obtained withdrawal of the order by the commission; Conducted internal investigations related to potential securities violations; Represented public companies in internal investigations relating to requests by FINRA focused on trading by potential insiders or tippees prior to merger and acquisition announcements; Represented investment adviser firm and associated individuals in FINRA investigation of securities trading; Counseled dually registered broker-dealer and investment adviser relating to changes in brokerage platform and advisory business; Represented firm in obtaining FINRA's approval of changes; Represented securities attorney in SEC investigation of unregistered securities offering and, after Wells notice had been given, persuaded SEC staff to drop the recommendation of charges; Advised public companies in comment letter process from SEC's Division of Corporation Finance regarding responses and revisions to filings required by SEC staff; Counseled public companies, including NYSE-listed and Fortune 1000 companies, regarding Regulation FD compliance including corrective disclosures and compliance procedures; Represented former public company and its private investor in SEC investigation of potential violations of the FCPA by a Chinese subsidiary; Represented SEC registered investment adviser in SEC investigation of securities trading strategies involving allegations of possible front-running or insider trading; Received termination letters indicating no action would be recommended by SEC staff; Counseled publicly traded companies regarding disclosure obligations surrounding government investigations and litigation; Advised public company regarding acquisition of an entity under investigation for potential FCPA violations; Represented two investment advisory firms in enforcement investigations by the Texas State Securities Board. |
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Documents by this lawyer on Martindale.com | |
“Why Cooperate with the SEC?” Recent Settlements Shed LightKit Addleman,Ben Johnson, April 18, 2012 Until recently, individuals considering cooperating with an SEC investigation had a difficult time determining whether a tangible benefit would result from cooperation. Two releases issued by the SEC in the past month demonstrate how the SEC has begun to apply its Cooperation Initiative and give...
Consumer Financial Protection Bureau Publishes Enforcement NoticeKit Addleman,F. John Podvin, November 18, 2011 On November 7, 2011, the Consumer Financial Protection Bureau (“CFPB”) announced that it will provide financial companies and individuals who are the subject of potential enforcement actions with an “Early Warning Notice Letter.” The CFPB’s letter and process is...
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