In this section, we describe the personal backgrounds and areas of concentration of George Brunelle, Esq. and Anna Hadjikow, Esq.
GEORGE BRUNELLE, a member of the firm, represents individuals and corporations in regulatory enforcement proceedings, arbitrations and lawsuits involving SEC and FINRA Rules in complex trading, operational and financial cases. Before entering private practice, he was employed for 11 years by the New York Stock Exchange where he managed a staff of attorneys conducting major investigations and enforcement proceedings for the NYSE's Market Surveillance Division. Mr. Brunelle is a graduate of Rutgers University and Brooklyn Law School and is admitted to practice before the the New York courts, as well as several of the U.S. District Courts, the U.S. Court of Appeals for the Second Circuit and the U.S. Supreme Court.
- Won dismissal in FINRA arbitration of multi-million claim against an NYSE market making firm and one of its executives.
- Won Not Guilty decision by the NYSE of a broker accused of failing to properly represent customer agency orders. Affirmed on appeal.
- Persuaded U.S. District Court in Manhattan to quash a Subpoena seeking the records of a broker-dealer organization.
- Obtained Not Guilty decision for a broker who had been accused of market manipulation and other offenses — affirmed on appeal.
- Obtained reversal by the U.S. Court of Appeals (Second Circuit) of sanctions against a securities broker, upon a finding that the SEC's penalty determination was an abuse of its discretion. Created new law on the subject.
- Obtained Not Guilty decision in favor of a securities broker who had been accused of effecting illegal ”wash sales.”
- Obtained Not Guilty decision in favor of a securities broker accused of initiating unlawful transactions on the NYSE Trading Floor and of making material misstatements of fact to investigators.
- Obtained Not Guilty decision in favor of a securities broker who had been accused of making false statements to an NYSE Floor Official.
- Obtained Not Guilty decision by a FINRA Hearing Panel in a case involving allegations against a firm trader that he had mishandled customer orders.
- Obtained waiver by the SEC of an investment advisor’s “bad actor” disqualification from participating in private placements under Regulation D.
- Obtained finding of non-liability in an FINRA arbitration proceeding against a broker accused of participating in a "raid" of another brokerage firm.
Each case depends on its own facts, and prior results do not guarantee similar outcomes with respect to future cases.
ANNA HADJIKOW is a member of the firm whose practice focuses on broker-dealer and investment adviser regulation, corporate and limited liability company law, commercial transactions, securities regulation, employment law, mergers and acquisitions of broker-dealers and other securities and investment entities, regulatory examinations, securities arbitration and securities litigation. Ms. Hadjikow was admitted to the Bar of the State of New York in 1995 and the U.S. District Court for the Southern District of New York in 1997.
Ms. Hadjikow was admitted to the Bar of the State of New York in 1995 and the U.S. District Court for the Southern District of New York in 1997. She attended Bernard M. Baruch College on a full tuition-academic scholarship, graduating cum laude in 1988, and obtained her J.D. degree from St. John's University School of Law in 1994. She is a member of the New York State Bar Association.
Ms. Hadjikow has over 20 years of experience in the formation, structuring, governance, licensing, financing and regulation of broker-dealers and investment advisers. She has represented numerous broker-dealers and investment advisers in virtually every aspect of their business dealings. Here areas of competency and experience include:
- mergers, acquisitions, reorganizations and consolidations of broker-dealers and investment advisers
- reorganizations of affiliated entities
- equity and asset purchases by broker-dealers and investment advisers
- shareholder and LLC operating agreements
- buy-sell agreements
- membership applications and regulatory licensing applications and agreements with the SEC, FINRA, and state regulators
- systems and procedures for compliance with Federal and state securities laws
- “new member applications” and “continuing membership” applications under FINRA Rule 1017 for business changes and expansions
- written supervisory procedures (“WSPs”) for new and specialized lines of business
- procedures for compliance with State and Federal employment laws
- transactions for the financing of new and ongoing business operations
- clearing agreements and systems
- anti-money laundering programs
- regulatory examinations, inquiries, investigations and disciplinary actions
- net capital and financial responsibility rules
- waivers of statutory disqualifications
- registration of BD’s and IA’s with State and Federal regulatory agencies
- investment adviser WSP’s
- executive employment and separation agreements
- “soft dollar” and “brokerage recapture” agreements
- net capital problems under SEC Rule 15c3-1
- 17a-11 notifications
- “FinOp” compliance and supervisory issues
- subordinated loan agreements
- research reports and other investment-related publications
- initial and amended Form ADV disclosures
- fidelity bond claims
- initial and amended disclosures on Forms BD, U-4, and U-5, and under FINRA Rule 3070
- “heightened supervision” programs
- “best execution” compliance
- expense sharing agreements with unregulated affiliates
- joint trading accounts
- consulting agreements