Brooke E. Conner

Brooke defends clients in connection with investigations, litigation and administrative proceedings conducted by the Securities and Exchange Commission (SEC), U.S. Attorney’s Office (DOJ), Financial Industry Regulatory Authority (FINRA) and other federal and state agencies.

Guiding clients through challenging, high-stakes matters threatening financial and reputational risks and business disruption, she achieves optimal outcomes with practical, business-oriented solutions that address her clients’ needs and meet their goals.

Brooke’s strategic, thoughtful approach allows her clients to confidently navigate what is often an unfamiliar and intimidating process. She swiftly identifies key issues and develops a comprehensive, efficient defense plan tailored to individual needs, risks and priorities. Ensuring each client is well-prepared and supported throughout the process, she streamlines investigations, frequently avoiding any government action or minimizing the scope of conduct and potential charges or penalties.

Brooke’s clients include public and private companies, investment advisers, broker-dealers, hedge funds, boards of directors, board committees and service providers, as well as officers, directors and other individuals facing investigation or government scrutiny. Clients rely on her at every stage, from initial inquiry or subpoena through resolution. She regularly conducts internal investigations on behalf of her clients, uncovers potential issues and provides remediation strategies, counsels regarding regulatory examinations and handles securities litigation and complex civil litigation matters.

Brooke also has extensive experience in investigations relating to alleged insider trading, conflicts of interest, books and records and internal controls violations, supervision, and whistleblower allegations, as well as financial restatements and other high-profile cases involving large-scale financial fraud or receiverships.

Experience

• Secured an SEC determination not to pursue an enforcement action against a large financial institution in connection with an SEC investigation arising out of an alleged massive valuation fraud by a third-party entity.
• Represented a former senior officer of a public company in connection with parallel DOJ and SEC investigations of securities fraud arising out of financial restatement.
• Successfully defended a broker-dealer client in parallel DOJ and SEC investigations involving insider trading and supervision issues after conducting an internal investigation. The matter entailed significant cooperation with government regulators on behalf of client, resulting in no enforcement action against the client.
• Secured an SEC determination not to pursue any enforcement action against a registered investment adviser, its parent company and various affiliated entities and individuals in connection with an SEC investigation concerning conflicts of interest and valuation of investments held by private funds managed by affiliates.
• Represented a former chief executive of a private company in an SEC litigation arising from alleged misrepresentations in investor disclosures regarding a SPAC transaction.
• Represented a former senior officer of a private company in connection with parallel DOJ and SEC investigations involving investor disclosures regarding a potential SPAC transaction, as well as related private litigation.
• Represented a leading financial technology company, one of its senior executive officers and an employee in connection with an SEC investigation involving insider trading that resulted in no enforcement action against the clients.