Experience

Gavin’s public- and private-sector roles give him a full view of the regulatory lifecycle. At FINRA, he served in the Office of General Counsel, providing guidance on complex regulatory initiatives and rulemakings and drafting regulatory guidance and rule filings submitted to the SEC. He also served in FINRA’s Office of Fraud Detection and Market Intelligence, conducting insider trading investigations. In-house, he advised business, supervision, and compliance teams on securities regulations and FINRA rules, including leading efforts tied to Regulation Best Interest implementation. At a start-up FinTech broker-dealer and crypto trading platform, he managed U.S. money transmitter licensing applications and advised on broker-dealer and crypto-related regulatory matters tied to product strategy, market structure, and growth. Before joining PierFerd, he also practiced in the financial regulatory practices of leading international law firms.

Practice Focus

• Broker-Dealers: Gavin’s broker-dealer practice spans status, formation, and day-to-day regulation. He counsels on SEC, FINRA, and state registration and licensing; exemptions and cross-border activities, including the issuer’s exemption, foreign finders, Rule 15a-6, and M&A brokers; and new and continuing membership applications. His work includes supervisory systems and written supervisory procedures, conflicts management and Regulation Best Interest, advertising and communications with the public, and books and records, including electronic communications and archiving. He advises on AML compliance; Reg S-P; financial responsibility, net capital, and customer protection; margin; clearing and execution; trade reporting; and compensation and revenue sharing structures.

• Investment Advisers: Gavin advises investment advisers on SEC and state registration, fiduciary duty and compliance program design, Form ADV and disclosures, the Marketing Rule’s advertising, solicitation, and referral requirements, and custody and safeguarding issues. He works closely with compliance and business teams to align policies, controls, and disclosures with evolving regulator guidance and industry practice.

• FinTech and Digital Assets: Gavin counsels a range of FinTech and digital asset businesses on perimeter and product issues. His work includes broker-dealer and investment adviser regulatory analysis, “security” status assessments for crypto assets and tokens, NFTs and intermediary arrangements, wallets and transfers, staking and DeFi considerations, AML/KYC frameworks, and state and federal money transmission and payments licensing. He emphasizes practical pathways for launch, scale, and risk management in fast-moving markets.

Rulemaking and Policy Engagement

Gavin helps clients engage constructively in rulemaking and policy through established public processes. He drafts and refines comment letters, prepares technical analyses, and participates in focused meetings and briefings with regulators and policymakers. He works with regulators to obtain interpretive guidance and targeted relief, including no-action and exemptive relief requests and other forms of agency guidance, and advises on implementation once guidance or rules are finalized. His approach is practical, informed by his regulatory background, and centered workable solutions.

Enforcement and Examinations

Gavin represents clients in SEC, FINRA, and state proceedings across the continuum from sweeps and routine exams to formal investigations and negotiated resolutions. He helps firms respond to regulator inquiries and FINRA Rule 8210 requests, prepare for testimony, develop remediation, and engage proactively with regulators to narrow issues and mitigate risk.