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Project on Government Oversight

Dangerous Liaisons: Appendix A

SEC Revolving Door Rankings

The following are facts and figures from the 1,949 post-employment disclosure statements filed by 419 Securities and Exchange Commission (SEC) alumni between 2001 and 2010.[1] All data can be found in the Project On Government Oversight’s “SEC Revolving Door Database.”[2]

SEC Alumni Who Filed the Most Disclosure Statements

Former SEC employees must notify the agency whenever they plan to represent a client or employer on a particular matter in the first two years after they leave.[3]

Some SEC alumni rarely interacted with the agency after they left, judging by the number of statements they filed. Other alumni dealt with the agency on a regular basis to represent parties on regulatory and enforcement matters.[4]

Table 1: Most Active SEC Alumni Ranked by
Number of Disclosure Statements Filed, 2001-2010

Name

Former
Division/Office

Former Title

New Employer

Disclosure
Statements Filed

William R. Baker III Enforcement Associate Director Latham & Watkins LLP 46
Kenneth L. Miller Enforcement Assistant Chief Litigation Counsel Bank of America 32
Brian J. Lane Corporation Finance Director Gibson, Dunn & Crutcher LLP 31
Thomas D. Shpetner Enforcement Branch Chief Lehman Brothers 31
Thomas A. Zaccaro Pacific Regional Office Regional Trial Counsel Akin, Gump, Strauss, Hauer & Feld LLP 26
Nicolas Morgan Enforcement Senior Trial Counsel DLA Piper 25
Charles S. Neal Enforcement Senior Counsel Wachovia 20
Walter G. Ricciardi Enforcement Deputy Director Paul, Weiss, Rifkind, Wharton & Garrison LLP 20
William E. Donnelly Trading and Markets Attorney Fellow LeClair Ryan 18
David M. Lynn Corporation Finance Special Counsel; Chief Counsel Wilmer Cutler Pickering Hale and Dorr LLP;
Morrison & Foerster LLP
18
Christian J. Mixter Enforcement Chief Litigation Counsel Morgan, Lewis & Bockius LLP 18
Melanie F. Dolan Corporation Finance Associate Chief Accountant KPMG LLP 17
Daniel A. Goldfried Enforcement Senior Counsel Merrill Lynch 17
Richard C. Sauer Enforcement Assistant Director Vinson & Elkins LLP 17
Erich T. Schwartz Enforcement Assistant Director Skadden, Arps, Slate, Meagher & Flom LLP 17
Stephen J. Crimmins Enforcement Deputy Chief Litigation Counsel Holland & Knight LLP; Pepper Hamilton LLP 16
Christine Davine Corporation Finance Associate Chief Accountant Deloitte LLP 15
Alison M. Fuller Investment Management Assistant Chief Counsel Stradley Ronon 15
Paul V. Gerlach Enforcement Associate Director Sidley Austin LLP 15
Brian A. Ochs Enforcement Assistant Director K&L Gates LLP 15
Russell G. Ryan Enforcement Assistant Director King & Spalding LLP 15
Eric M. Schmidt Northeast Regional Office Assistant Regional Director Salomon Smith Barney Inc. 15
Joaquin M. Sena Enforcement Assistant Chief Litigation Counsel Bank of America 15

SEC Alumni Who Filed First Disclosure Statement Within One Week of Leaving

Many SEC alumni can represent clients before the agency immediately after leaving, as long as they comply with all relevant federal ethics rules. More than 20 alumni contacted the agency within one week of leaving, according to records obtained by POGO.[5]

Table 2: SEC Alumni With Shortest Time Between
Departure and Filing of First Disclosure Statement, 2001-2010

NameFormer Division/OfficeFormer TitleNew EmployerDays Between
Departure and Filing First Disclosure Statement
Matthew A. Beller Los Angeles Regional Office Examiner CPS Partners, LLC 2
Larry P. Ellsworth Enforcement Assistant Chief Litigation Counsel Jenner & Block 2
John R. Fahy Enforcement Attorney Fiserv Investor Services, Inc.; Tradestar Investments, Inc. 3
John C. Ivascu Enforcement Staff Attorney Vinson & Elkins LLP 3
David M. Levine Enforcement Senior Advisor Deutsche Bank AG 3
Richard C. Sauer Enforcement Assistant Director Vinson & Elkins LLP 3
Andrew M. Lawrence Enforcement Staff Attorney Skadden, Arps, Slate,
Meagher & Flom LLP
4
Derek M. Meisner Enforcement Branch Chief K&L Gates LLP 4
Erich T. Schwatz Enforcement Assistant Director Skadden, Arps, Slate,
Meagher & Flom LLP
4
Christopher T. Stidvent Enforcement Staff Attorney Dell Inc. 4
Douglas J. Davison Office of Chairman
Arthur Levitt
Counsel Wilmer Cutler Pickering
Hale and Dorr LLP
5
Daniel A. Goldfried Enforcement Senior Counsel Merrill Lynch 5
Charles S. Neal Enforcement Senior Counsel Wachovia 5
Steven E. Richards Enforcement Assistant Chief Accountant FTI Consulting, Inc. 5
Lindi L. Beaudreault Enforcement Senior Counsel LeClair Ryan 6
Alan Reifenberg Enforcement Branch Chief Credit Suisse 6
Patrick K. Craine Enforcement Staff Attorney Munsch Hardt Kopf & Harr, P.C. 7
Christopher M. Cutler Enforcement Senior Counsel Sutherland Asbill & Brennan LLP 7
Mary E. Gardner Enforcement Senior Counsel McDermott Will & Emery LLP 7
Kelly A. McCormick Enforcement Senior Counsel Crowell & Moring LLP

7

Sandeep Savla Enforcement Senior Counsel Wiggin & Dana, LLP 7

Top Recruiters of SEC Alumni

Some large firms have emerged as top recruiters of SEC alumni, and many of their hires appear before the agency on behalf of the firms or their clients.

Table 3a: Top Recruiters of SEC Alumni Ranked by
Number of Alumni Who Filed Disclosure Statements, 2001-2010

Firm [6]SEC Alumni Who Identified Firm As New Employer
ACA Compliance Group 16
Wilmer Cutler Pickering Hale and Dorr LLP 16
Deloitte LLP 14
Ernst & Young 12
KPMG LLP 12
Morgan, Lewis & Bockius LLP 11
Dechert 8
Morrison & Foerster LLP 8
O'Melveny & Myers LLP 8
K & L Gates LLP 7
Sidley Austin LLP 7
Skadden, Arps, Slate, Meagher & Flom LLP 7
Public Company Accounting Oversight Board 6
Deutsche Bank AG 5
DLA Piper 5
Gibson, Dunn & Crutcher LLP 5
PricewaterhouseCoopers LLP 5
Venable LLP 5
Wilson Sonsini Goodrich & Rosati, P.C. 5

Table 3b: Top Recruiters of SEC Alumni Ranked by
Number of Mentions in Disclosure Statements, 2001-2010

Firm
Disclosure Statements Identifying
Firm as New Employer
Wilmer Cutler Pickering Hale and Dorr LLP 68
Sidley Austin LLP 61
Deloitte LLP 60
Latham & Watkins LLP 54
DLA Piper 48
O'Melveny & Myers LLP 48
Bank of America 47
Morgan, Lewis & Bockius LLP 47
Skadden, Arps, Slate, Meagher & Flom LLP 46
Gibson, Dunn & Crutcher LLP 44
K & L Gates LLP 43
KPMG LLP 43
Ernst & Young 41
Lehman Brothers 39
LeClair Ryan 37
ACA Compliance Group 33
Paul, Weis, Rifkind, Wharton & Garrison LLP 32



SEC Divisions and Offices Where Alumni Used to Work

SEC regulations require alumni to identify their former division or office in the disclosure statements. The Enforcement Division was mentioned most often in disclosure statements filed between 2001 and 2010 (it is also the largest division at the SEC).[7]

Table 4: Former Divisions and Offices of SEC Alumni Who Filed Disclosure Statements, 2001-2010

Division/Office
SEC Alumni Who Worked in
this Division Office [8]
Disclosure Statements Filed
Enforcement 172 1032
Regional Offices 52 213
Office of the Chief Accountant 47 146
Corporation Finance 46 236
Investment Management 32 111
Trading and Markets 25 89
Compliance Inspections and Examinations 17 35
General Counsel 8 33
Office of Commissioner Roel C. Campos 4 9
Economic Analysis 3 3
Office of Chairman Christopher Cox 3 9
Office of Commissioner Paul R. Carey 3 9
Executive Director 2 2
Office of Chairman Arthur Levitt 2 6
Office of Commissioner Laura S. Unger 2 4
International Affairs 1 1
Office of Chairman Harvey L. Pitt 1 4
Office of Chairman William H. Donaldson 1 7

Some of these statements were filed by alumni who served in the most senior positions at the agency, including a former commissioner, three former enforcement directors, four former corporation finance directors, a former trading and markets director, [9] and two former general counsels. [10]

Yearly breakdown of disclosure statements

There were 341 disclosure statements filed in 2001, the most filed in any year between 2001 and 2010. These 341 statements were filed by 91 SEC alumni. In 2006, there were more alumni who filed statements (96), but they filed fewer statements (255) compared to 2001.[11]

Table 5: Yearly Breakdown of Disclosure Statements Filed by SEC Alumni, 2001–2010

YearSEC Alumni [12]Disclosure Statements Filed
2001 91 341
2002 61 193
2003 52 185
2004 59 205
2005 77 235
2006 96 255
2007 76 196
2008 55 108
2009 36 101
2010 34 130


Endnotes

 [1] Project On Government Oversight, web page containing SEC post-employment disclosure statements filed from 2001 to 2010.

 [2] Project On Government Oversight, “SEC Revolving Door Database.”

 [3] “Practice by former members and employees of the Commission,” 17 C.F.R. § 200.735-8(b).  (Downloaded November 26, 2012)

 [4] Some SEC alumni identified multiple issues within a single disclosure statement. For instance, David Kornblau, a former SEC chief litigation counsel, filed one statement in which he disclosed his plans to represent Merrill Lynch in connection with 17 separate enforcement matters pending before the agency. The statement does not indicate how many times Kornblau ended up contacting the agency to discuss these matters. Letter from David L. Kornblau, First Vice President and General Counsel, Global Regulatory Affairs, Merrill Lynch, to Nancy Morris, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), January 11, 2006.

 [5] Letter from David M. Levine, Director, Legal Department, Deutsche Bank AG, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding statement by a former employee pursuant to Rule 8(b) of the Commission’s conduct regulation, December 3, 2001. Letter from Matthew A. Beller, GPS Partners LLC, to Nancy M. Morris, Secretary, Securities and Exchange Commission, regarding statement of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), March 3, 2008. Letter from Larry P. Ellsworth, Jenner & Block, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), August 2, 2005. Letter from John R. Fahy, General Counsel and Senior Vice-President, Fiserv Investor Services, Inc., Tradestar Investments, Inc., to Jonathan G. Katz, Secretary, Securities and Exchange Commission, regarding notice of possible appearance before the Commission pursuant to 17 C.F.R. 200.735-8(b)(1) and (2), September 13, 2004. Letter from John C. Ivascu, Associate, Vinson & Elkins, L.L.P., to Nancy Morris, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), January 5, 2006.  Letter from Richard C. Sauer, Vinson & Elkins, L.L.P., to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), June 12, 2003. Letter from Andrew M. Lawrence, Skadden, Arps, Slate, Meagher & Flom LLP, to Jonathan G. Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), March 2, 2004. Letter from Derek M. Meisner, Kirkpatrick & Lockhart LLP, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), July 27, 2004.  Letter from Erich T. Schwartz, Skadden, Arps, Slate, Meagher & Flom LLP, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), April 17, 2001. Letter from Christopher T. Stidvent, Dell, to Nancy M. Morris, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), September 5, 2006. Letter from Douglas J. Davison, Wilmer, Cutler & Pickering, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), April 4, 2001.  Letter from Daniel A. Goldfried, Merrill Lynch, to Nancy Morris, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), March 7, 2007. Letter from Charles S. Neal, Vice President, Assistant General Counsel, Wachovia Corporation, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), February 4, 2004.  Letter from Steven E. Richards, Managing Director, FTI Consulting, Inc., to Florence Harmon, Acting Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), July 16, 2008. ;Letter from Lindi L. Beaudreault, LeClair Ryan, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), May 1, 2003.  Letter from Alan Reifenberg, Credit Suisse Securities (USA) LLC, to Nancy M. Morris, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), June 15, 2006. Letter from Patrick K. Craine, Munsch Hardt Kopf & Harr, PC, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), June 30, 2005.  Letter from Christopher M. Cutler, Sutherland Asbill & Brennan LLP, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding statement by a former employee pursuant to Rule 8(b) of the Commission’s conduct regulation, June 26, 2003.  Letter from Mary E. Gardner, McDermott Will & Emery, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), June 25, 2004.  Letter from Kelly A. McCormick, Crowell & Moring, LLP, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), August 15, 2003.  Letter from Sandeep Savla, Wiggin and Dana, to Jonathan Katz, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), January 30, 2004.

 [6] Some of the firms that hired SEC alumni have gone through mergers or acquisitions. Other firms are different subsidiaries of the same corporate parent. Wherever possible, POGO tried to record the latest name of the firm (e.g., the law firm of “Wilmer, Cutler & Pickering” is recorded under its current, post-merger name, “Wilmer Cutler Pickering Hale & Dorr”), or the name of the corporate parent (e.g., “Deutsche Bank Securities” is recorded under the name of its corporate parent, “Deutsche Bank AG”).

 [7] Securities and Exchange Commission, In Brief: FY 2013 Congressional Justification, February 2012, p. 12.  (Downloaded December 2, 2012)

Many SEC employees work at the agency’s headquarters in Washington, DC. Others are located at one of the SEC’s 11 regional offices. Securities and Exchange Commission, “Securities and Exchange Commission Organization Chart.” f (Downloaded January 4, 2013)

POGO’s database lists only the functional division or office in which SEC alumni used to work, regardless of where they were located. For instance, one alumnus might have worked for the Enforcement Division in the agency’s Washington, DC, headquarters, while another might have worked for the Enforcement Division in the agency’s New York office. Both alumni would simply be listed under the Enforcement Division in POGO’s database.

In some disclosure statements, alumni said where they used to work, but did not identify a functional division or office. For instance, Kit Addleman only disclosed that she was a regional director of the SEC’s Atlanta office. As a regional director, she apparently oversaw multiple functions, according to a bio posted on the website of the law firm where she currently works. In POGO’s database, her former division/office is marked simply as “Regional Office.” Letter from Kit Addleman, Haynes and Boone, LLP, to Elizabeth M. Murphy, Secretary, Securities and Exchange Commission, regarding notice of representation pursuant to Rule 8(b), 17 C.F.R. 200.735-8(b), December 23, 2010.  Haynes and Boone, LLP, “Kit Addleman.”  (All downloaded January 4, 2013)

In Table 4, the category of “Regional Offices” covers Addleman and other SEC alumni who worked outside of the agency’s headquarters but did not identify whether they reported to a single functional division or office.

If an alumnus worked in several different divisions or offices during her time at the agency, POGO recorded the division or office where she was most recently employed.

 [8] POGO’s database includes disclosure statements filed by 419 unique alumni from 2001 to 2010. However, there are 421 alumni listed in Table 4. The reason for the discrepancy is that two alumni—Jon Kroeper and Erik R. Sirri—worked in different divisions/offices during two separate stints at the SEC.

 [9] There were disclosure statements filed by two alumni—Paul S. Maco and Erik R. Sirri—who used to be directors in the SEC’s Trading and Markets Division. But Maco was the director of a smaller office within the division; he was not in charge of the division as a whole. Securities and Exchange Commission, “Paul Maco, First Director of the Office of Municipal Securities, Returns to Private Practice After Six and One-Half Years of Service,” September 27, 2000.  Securities and Exchange Commission, “Office of Municipal Securities,” July 31, 2012.  (All downloaded January 17, 2013)

 [10] Project On Government Oversight, web page containing SEC post-employment disclosure statements filed by former commissioners.  Project On Government Oversight, web page containing SEC post-employment disclosure statements filed by former enforcement directors.  Project On Government Oversight, web page containing SEC post-employment disclosure statements filed by former corporation finance directors.  Project On Government Oversight, web page containing SEC post-employment disclosure statements filed by former trading and market directors.  Project On Government Oversight, web page containing SEC post-employment disclosure statements filed by former general counsels.

 [11] Project On Government Oversight, web page containing SEC post-employment disclosure statements filed in 2001.  Project On Government Oversight, web page containing SEC post-employment disclosure statements filed in 2006.

 [12] POGO’s database includes disclosure statements filed by 419 unique alumni from 2001 to 2010. Some of these alumni filed statements across multiple years. For instance, an employee who left the SEC in 2006 might have filed statements in 2006, 2007, and 2008. This alumnus would have only been counted once in the total figure of 419, but he would be represented across multiple years in Table 5. This explains why the total number of former employees listed in Table 5 is greater than 419.