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1152 Fifteenth Street, NW, Suite 850
Washington, D.C. 20005
United States of America
P: +1 202.729.7462
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Ida Wurczinger Draim is a partner in the Washington, D.C. office. Her practice focuses on securities and commodities compliance counseling and the representation of securities industry and corporate clients in regulatory investigations and proceedings. With more than 25 years of experience, Ida is well known for her expertise in investment adviser and broker-dealer compliance and her highly effective representation of industry clients before the SEC, NYSE, FINRA, CFTC, NFA and other regulatory authorities. Some of the areas that Ida regularly addresses on behalf of our investment adviser clients include conflicts of interest, Form ADV disclosure, third-party marketing arrangements, soft dollar practices, personal trading compliance, principal and agency trades, advertising, valuation, best execution, custody, trading restrictions and prohibitions, and commodity pool operator registration and regulatory issues. In the broker-dealer context, Ida regularly deals with Regulations NMS and SHO, best execution, dark pools, prime brokerage functions, institutional and retail sales practices, insider trading and rumors, marketing materials, research, short sale restrictions, supervisory structure, trade surveillance and monitoring, and statutory disqualifications. In addition to compliance counseling and regulatory representation, Ida routinely supervises mock audits, advises clients undergoing regulatory examinations and inspections, provides compliance training and develops supervisory and compliance policies and procedures.
One of Ida’s strengths is that she has experienced securities regulation from both sides of the aisle. After several years as a securities litigation associate with a Wall Street law firm, Ida joined the SEC, first serving as staff attorney in the Division of Enforcement, where she earned a Special Achievement award, then as Special Counsel to SEC Chairman John Shad. Ida is a member of the FINRA (formerly NASD) Board of Arbitrators and Board of Mediators and, for 10 years (ending January 2009), served as a member of the Nasdaq Listing Qualifications Panel. She is also a panelist and member of the Securities Industry and Financial Markets Association (SIFMA) Legal and Compliance Division and a former Chair of the Corporation, Finance and Securities Law Section of the District of Columbia Bar. Ida received her J.D. from Harvard Law School and her B.A., cum laude, from Rutgers University. She has been recognized by The Best Lawyers in America in the area of securities law.
Selected Representations
Successfully represented a West Coast-based clearing firm in an NASD (now FINRA) arbitration brought by a bio-venture capital firm from which $15 million worth of securities on deposit with the clearing firm had allegedly been converted by a foreign business partner. The case raised novel issues regarding the application of the “safe harbor” under U.C.C. § 8-115. (Medical Assets, LLC v. Emmet A. Larkin Co., Inc.)
Successfully represented National Discount Brokers, a former division of Deutsche Bank, in an NASD arbitration proceeding against it involving more than $12 million in losses resulting from a correspondent firm’s failure to cover a large short position in a highly volatile stock. The case raised significant issues regarding the responsibility of clearing firms and Nasdaq market makers with respect to monitoring the risk exposure of correspondent firms. (Weiss, Peck & Greer, L.L.C. v. National Discount Brokers)
Represented SIFMA (formerly SIA), as amicus curiae on behalf of the successful appellees, in the first federal case in which a pre-dispute arbitration agreement was held enforceable against the receiver for the institutional customers who executed the agreement. (Javitch v. First Union Securities, Inc.)
Successfully litigated the first case on whether viatical settlements constitute “securities” within the federal securities laws. (SEC v. Life Partners, Inc.)
Represented former CEO of Drexel Burnham Lambert, Inc. in key SEC and NYSE cases on broker-dealer supervision. (In the Matter of Frederick H. Joseph)
Obtained seminal SEC no-action letter on securities/insurance networking arrangements. (The Wolper Ross Corporation)
Selected Publications
“Protecting Your Firm Through Policies and Procedures, Training and Testing,” Insider Trading Law and Compliance Answer Book (Practising Law Institute) October 2011 (co-author)
“Trade Reporting and Compliance,” Practitioner’s Guide for Broker-Dealers (Complinet) Nov. 11, 2010
More
Selected Speaking Engagements
“Compliance Spotlight” and “Regulatory and Compliance,” SRZ 21st Annual Private Investment Funds Seminar, New York, January 2012
“Proposed CFTC Filing Requirements,” Hedge Fund CFO Association Membership Meeting, New York, May 2011
“How to Comply with Rule 105: A Workshop for Hedge Fund Managers,” SRZ Investment Management Hot Topics, New York, May 2011
“US Regulatory Issues for Non-US Managers,” SRZ Audio Conference Series, April 2011
“Compliance & Diligence for Allocators,” Goldman Sachs 4th Annual Managed Account Seminar, New York, March 2011
Goldman Sachs SEC/CFTC Proposed Form PF and CPO/CTA Exemptions Teleconference, February 2011
“High-Frequency Trading and Regulation,” Deutsche Bank Unlocking the Black Box Seminar, New York, February 2011
“Compliance Spotlight” and “Managing Compliance Strategically,” SRZ 20th Annual Private Investment Funds Seminar, New York, January 2011
“Private Equity Investment Adviser Registration,” SRZ Investment Management Hot Topics, New York, December 2010
AIFEA Private Equity and Venture Capital Funds Boot Camp, New York, November 2010
“Hedge Fund Operations Best Practices: Dealing with Increased Volatility and Transparency Peer Group Workshop for Fund Managers,” 25th Annual Fall Investment Adviser and Broker-Dealer Compliance Conference, Scottsdale, AZ, October 2010
“Managing Compliance Strategically,” SRZ Investment Management Hot Topics, New York, October 2010
“Top 10 Compliance Issues for CFO's,” Hedge Fund CFO Association Membership Meeting, New York, April 2010
“Spotlight on Compliance: Key Issues for 2010,” SRZ 19th Annual Private Investment Funds Seminar, New York, January 2010
“Preparing for SEC Examinations of Private Fund Advisers,” SRZ Investment Management Hot Topics, New York, November 2009
“Financial Services Reform: How Will It Impact Hedge Funds, Private Equity Funds, and Venture Capital Firms,” NRS Strategies for Successfully Navigating the Twin Challenges of Regulatory Reform and Risk Management, Las Vegas, November 2009
“Proposed Investor Protection Act of 2009” and “Private Fund Investment Advisers Registration Act of 2009,” ABA Institutional Investors Committee: Potential Impact of Financial Regulatory Reform on Investors, Washington, D.C., October 2009
“Preparing for SEC Registration and New Reporting Requirements,” SRZ Investment Management Hot Topics, New York, September 2009
“Operational Risk Management Part 2: Proactive Problem Management When Bad Things Happen – Effectively Dealing with Breaches, Misconduct and Internal Investigations,” NRS Desktop Webinar, August 2009
“Spotlight on Compliance: Key Issues for 2009,” SRZ 18th Annual Private Investment Funds Seminar, New York, January 2009
“Market Rumors, Short Selling and Current Regulatory Focus,” SRZ Investment Management Hot Topics, New York, October 2008
More
Memberships
FINRA Board of Arbitrators
FINRA Board of Mediators
Nasdaq Listing Qualifications Panelist
SIFMA, Legal and Compliance Division, panelist and member
DC Bar Corporation, Finance and Securities Law Section, former Chair
Other Distinctions
Recognized in The Best Lawyers in America in the area of securities law
SEC Special Achievement Award
Bar Admissions
- District of Columbia
- New York
Court Admissions
- U.S. Court of Appeals, Sixth Circuit 1997
- U.S. Court of Appeals, District of Columbia 1997
- U.S. District Court, District of Columbia 1991
- U.S. District Court, Eastern District of New York 1982
- U.S. District Court, Southern District of New York 1982
Education
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Harvard Law School, J.D., 1981
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Rutgers University, B.A., cum laude, 1977
Prior Experience
Dickstein Shapiro LLP
Partner
Wiley Rein & Fielding LLP
Partner
Sullivan & Cromwell LLP
Associate
U.S. Securities & Exchange Commission
Staff Attorney, Division of Enforcement
Special Counsel to Chairman John Shad