Mr. Dombach’s practice focuses on providing regulatory guidance to exchanges, trading and advisory firms, and related individuals and assisting those entities and individuals in regulatory inquiries.  He regularly advises trading platforms, broker-dealers, clearing agencies, and other clients on a variety of compliance, regulatory, and transactional matters, and interfaces with the staff of the SEC and other regulatory bodies on behalf of clients.  His work involves complex trading and markets issues, including advising clients with respect to compliance with Reg. NMS, Reg. ATS, and Reg. SHO, as well as the defense of trading-related SEC and SRO investigations.

Representative Matters

Acting as Counsel and Secretary for Operating Committees of National Market System Plans

Assisting firm and individuals related to SEC and FINRA reviews/investigations of Alternative Trading Systems

Advising broker-dealer on compliance issues related to Reg. NMS and Reg. SHO

Drafting proposed SRO pilot plan to increase tick size on behalf of FINRA and several national securities exchanges to increase tick size

Assisting leading national securities exchange in investigation by the SEC Division of Enforcement related to exchange order type functionality, which concluded with a formal closing letter from the Division

Assisting a leading global derivatives marketplace with respect to securities regulatory matters before the SEC Division of Trading and Markets

Assisting a major equity market participant in responding to a New York Attorney General’s Office subpoena related to high frequency trading issues

Filing of petition to SEC on behalf of leading Options Market Maker regarding approval of capital-raising plan proposed by Options Clearing Corporation

Publications

• Securities and Exchange Commission Proposes Access Fee Pilot Affecting All NMS Stocks
  (03/16/2018)
  
• SEC’s Ultimatum to Token Platforms is No Choice at All: Register as an ATS or Go Out of Business
  (Co-authored with Matthew B. Comstock)
  (03/14/2018)
  
• States Leading the Way in Developing Regulatory Approach to Utility Tokens
  (03/08/2018)
  
• What is a Regulation SHO bona-fide market maker?
  (Co-authored with Larry E. Bergmann)
  Journal of Investment Compliance | (2017)
  
• FIRREA Threatens to Add to Government's Financial Crisis Arsenal
  (Co-authored with James K. Goldfarb)
  American Bar Association | (01/03/2014)
  

Seminars and Presentations

• Murphy & McGonigle 2018 CLE Breakfast Series: Best Execution & Pricing (Equity & Fixed Income)
  10/04/2018