Michael Greene

Michael Greene is a Bates Group Consulting and Testifying Expert who has more than 35 years of experience in securities and broker-dealer regulation. He offers expertise in FINRA and SEC rules including those related to suitability, Reg BI, supervision, sales practice, markups, order handling, trade reporting, net capital, customer protection, and advertising. 

He has served in a variety of roles with FINRA, including as Counsel to FINRA’s Internal Audit Department, where he was responsible for providing legal guidance to Internal Audit staff regarding FINRA rules and regulations. He planned and conducted audits of FINRA businesses including regulatory units and conducted internal investigations of FINRA activities. 

Michael served as an Attorney/Special Investigator with FINRA’s Enforcement Department where he conducted investigations to determine if FINRA members violated FINRA rules and prepared memoranda summarizing investigative results and analyzing the applicable law. He was an Analyst with FINRA’s Market Regulation Department where he conducted insider trading and market manipulation investigations, one of which received national recognition and another that resulted in the felony conviction of three individuals. Michael was an Analyst with FINRA’s Corporate Financing Department where he reviewed offering documents submitted by FINRA members in connection with securities offerings to ensure compliance with FINRA rules. He began his career as an Examiner in FINRA’s New York District Office where he conducted on-site financial and regulatory audits of FINRA members. He authored an article on the scope of NASD Rule 2010 (now FINRA Rule 2110) regarding the just and equitable principles of trade that FINRA members and their associated persons must follow.

Michael was an Attorney with the SEC’s Division of Market Regulation where he provided interpretive guidance concerning SEC Rules 15c3-1 (the Net Capital Rule), 15c3-3 (the Customer Protection Rule), and 17a-3 and 17a-4 (the Books and Records Rules). He assisted in drafting rules proposed by the SEC, including a rule regulating Credit Rating Agencies.

In addition to his FINRA and SEC experience, Michael was an attorney for NASDAQ, where he advised the NASDAQ Listing and Hearing Review Council on matters appealed from decisions of the NASDAQ Listing Qualifications Panel regarding the listing status of issuers’ securities and drafted the decisions issued by the NASDAQ Listing and Hearing Review Council on matters appealed by issuers. He provided oral and written interpretive advice to issuers and their counsel regarding NASDAQ’s listing qualifications rules, including its corporate governance rules, and investigated the accuracy and adequacy of the financial statements and other public disclosures of NASDAQ issuers.

Michael was an attorney in private practice where he advised broker-dealers regarding regulatory matters involving the SEC, NASD, NYSE, state securities regulators, and the Board of Governors of the Federal Reserve System. He served as an Intern during law school for the Securities Division of the Office of the Maryland Attorney General.