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Holly H. Smith

Partner
Senior Counsel

Holly began her legal career in the financial services sector as an attorney with the SEC. 

In her 13 years with the SEC, she served as counsel to Commissioner Mary L. Schapiro for approximately five years and later was appointed an associate director in the Division of Market Regulation (now the Division of Trading and Markets). Her responsibilities included oversight of the U.S. stock exchange, options and over-the-counter markets and certain rulemakings under the Securities Exchange Act of 1934. She worked extensively on sales practice, compliance and market structure issues, including the development and adoption of rules for the handling of customer orders and the treatment of quotations entered into electronic communications networks. In addition, she advised the SEC on matters relating to the sale of over-the-counter derivatives.

  • Represented Securian Financial Group, Inc. in the auctioned sale of its retirement plan recordkeeping business to Standard Insurance Company.
  • Assists legal entities with US registration and licensing, including FINRA membership.
  • Advises on all issues relevant to trading, including the status of various platforms and technologies under US law.
  • Advises on whether or not a product (cryptocurrency or digital asset) is considered a security by US regulatory bodies (SEC and state).
  • Represented Empower in its acquisition of MassMutual’s retirement services business for a total transaction value of $3.35 billion.
  • Represented Empower in its acquisition of Prudential’s retirement plan business for a total transaction value of $3.55 billion.
  • Represents broker-dealers buying or selling their businesses or selected assets, such as a line of business.
  • Dual Registrant Regulatory Summit: Standard of Conduct – Where do we go from here? April 20, 2021
  • Securities Law and Practice 2020: How the SEC Works, October 6, 2020, Practising Law Institute
  • Unclaimed Property: The Great Treasure Hunt Continues, September 30, 2020
  • Regulation Best Interest, Form CRS and Interpretive Guidance Under the Advisers Act, September 25, 2019, Envestnet
  • NSCP Webcast: Reg BI: What Does it Mean for Compliance? June 28, 2019, The National Society of Compliance Professionals (NSCP)
  • Dual registrants roundtable: Working through the SEC's new standard of conduct rules, June 27, 2019
  • Briefing call: New SEC rule set on financial professional standard of conduct and fiduciary duty, June 7, 2019
  • Diminished Capacity Issues for Investors and Advisors, March 25, 2019, SIFMA C&L Annual Seminar
  • Planning for a patchwork of best interest standards – recent developments, February 27, 2019
  • Recognized by The Legal 500 United States in the area of financial services: regulatory (2015, 2018-2020, 2022) and financial services regulation: broker-dealers (2023)
  • Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of financial services regulation (2012-2023)
  • Recipient, SEC Law and Policy Award from SEC Chairman Richard Breeden
  • Recipient, Award by SEC Chairman Arthur Levitt for her work on the SEC’s order handling rules
  • Member, Broker-Dealer Legal and Regulatory Affairs Subcommittee, National Society of Compliance Professionals (NSCP)
  • Former Member, Board of Directors, NSCP
  • District of Columbia
  • B.A., Georgetown University
  • J.D., The Catholic University of America, Columbus School of Law
Holly Smith

Partner

Senior Counsel

Holly Smith

Partner

Senior Counsel

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