Cliff focuses his practice on investment management and leads the Eversheds Sutherland (US) investment services group.
Cliff brings more than 30 years of regulatory, in-house and private practice experience to his work counseling financial services clients regarding the comprehensive regulations governing asset managers, broker-dealers, investment advisers and bank fiduciaries. He works with clients on various types of investment vehicles in the retail and retirement market including managed advisory programs, insurance investment funds, registered investment companies and bank collective investment trusts.
Cliff routinely guides clients through US Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA) and state securities departments in connection with regulatory and examination matters. Cliff also works regularly with the preeminent securities, retirement and insurance industry trade associations, and serves as policy counsel to the Financial Services Institute (FSI), which is the industry trade association for independent broker-dealers. He is often called upon to represent a wide range of firms (including securities broker-dealers and asset managers) and leading industry trade associations on regulatory reform issues and often assists clients in connection with rulemaking and policymaking before federal regulators.
Cliff began his career at the SEC, rising to the position of Assistant Director at the agency’s Division of Investment Management and then served as chief legal officer for over ten years to one of the county’s largest dual-registrants. Cliff also serves as editor of the Practising Law Institute’s blog, BD/IA: Regulation in Focus, which provides legal perspectives on current regulatory developments for broker-dealers and investment advisers.
In addition to his work at Eversheds Sutherland, Cliff is heavily involved in the community. In 2012, he co-founded the Julia Anne Kirsch Foundation, which seeks to serve the needs of disabled individuals and their families.
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- Provided counsel regarding the development of one of the first “clean share” mutual funds.
- Advised financial institutions and payment processors providing services to cannabis businesses on potential liability under the Money Laundering Control Act and the Controlled Substances Act.
- Fundamentals of Broker-Dealer Regulation, July 17, 2023, Practising Law Institute
- Author and editor of two of the leading treatises in the broker-dealer and adviser arena, Broker-Dealer Regulation and Investment Adviser Regulation (published by the Practising Law Institute)
- Financial Services RegTech and Regulatory Compliance Forum 2021, November 15, 2021, Practising Law Institute
- Fundamentals of Broker-Dealer Regulation 2021, July 19, 2021, Practising Law Institute
- Fundamentals of Investment Adviser Regulation 2021, June 21, 2021, Practising Law Institute
- Advisers Act Regulatory Update Series, June 17, 2021
- Task Force on Climate-Related Financial Disclosures (TCFD): An Introductory Guide for US Corporates, May 13, 2021
- Basics of Mutual Funds and Other Registered Investment Companies 2021, April 21, 2021, Practising Law Institute
- Dual Registrant Regulatory Summit: Standard of Conduct – Where Do We Go From Here?, April 20, 2021
- Asset Management Regulatory Update Series, April 1, 2021
- Advisers Act Regulatory Series: 2021 First Quarter Update, March 11, 2021
- The SEC’s Overhaul of the Investment Adviser Advertising and Solicitation Rules: Your Questions Answered, March 5, 2021
- The SEC’s Overhaul of the Investment Adviser Advertising and Solicitation Rules: Solicitor Relationships, February 3, 2021
- Dually Registered Broker-Dealers and Advisers – Regulatory, Compliance and Enforcement 2021, February 1, 2021, Practising Law Institute
- The SEC’s Overhaul of the Investment Adviser Advertising and Solicitation Rules: Issues for Dual Registrants Under the Amended Rules, January 27, 2021
- The SEC’s Overhaul of the Investment Adviser Advertising and Solicitation Rules: Overview of the Rule Amendments, January 13, 2021
- Advisers Act Regulatory Series: 2020 Fourth Quarter Update, December 10, 2020
- Financial Services RegTech and Regulatory Compliance Forum 2020, November 23, 2020, Practising Law Institute
- Fund Finance 2020, November 11, 2020, Practising Law Institute
- Bank Fiduciary Activities and Collective Investment Funds 2020, October 27, 2020, Practising Law Institute
- Asset Management Regulatory Update Series, October 22, 2020
- Securities Law and Practice 2020: How the SEC Works, October 6, 2020, Practising Law Institute
- Global Asset Management 2020, September 30, 2020, Practising Law Institute
- Fundamentals of Investment Adviser Regulation 2020, September 23, 2020, Practising Law Institute
- Fundamentals of Broker-Dealer Regulation 2020, July 13, 2020, Practising Law Institute
- ESG Investing for Asset Managers – The Legal Framework, June 9, 2020
- Regulatory Actions, Government Investigations and Litigation in a Post-Coronavirus World: Part II – SEC and FINRA Regulatory, Examination, and Enforcement Priorities and Processes, April 6, 2020
- Form ADV 2020 Tune-Up, March 18, 2020, Practising Law Institute
- Quick Call: Preparing for the 2020 ADV Season, March 12, 2020
- Advisers Act Regulatory Series: 2020 First Quarter Update, March 11, 2020
- Fiduciary Investment Advice 2020, February 5, 2020, Practising Law Institute
- Hot Topics for Advisers to Collective Investment Trusts, February 4, 2020
- Advisers Act Regulatory Series: 2019 Fourth Quarter Update, December 12, 2019
- Financial Services RegTech and Regulatory Compliance Forum 2019, November 21, 2019, Practising Law Institute
- Bank Fiduciary Activities and Collective Investment Funds 2019, October 29, 2019, Practising Law Institute
- Securities Law and Practice 2019: How the SEC Works, October 17, 2019, Practising Law Institute
- Advisers Act Regulatory Series: 2019 Third Quarter Update, September 26, 2019
- Global Investment Funds 2019, September 9, 2019, Practising Law Institute
- The CFP Board’s New Standards of Conduct – Important Considerations for Broker-Dealers and Investment Advisers, July 24, 2019
- The SEC’s New Standard of Conduct Rules – Important Considerations for Bank-Affiliated Broker-Dealers and Investment Advisers, July 23, 2019
- Fundamentals of Broker-Dealer Regulation 2019, July 22, 2019, Practising Law Institute
- FSI Webcast: The SEC’s New Standard of Conduct Rules – Important Considerations for Independent Financial Services Firms, July 18, 2019, Financial Services Institute
- Fundamentals of Investment Adviser Regulation 2019, July 8, 2019, Practising Law Institute
- Dual Registrants Roundtable: Working Through the SEC's New Standard of Conduct Rules, June 27, 2019
- Advisers Act Regulatory Series: 2019 Second Quarter Update, June 20, 2019
- Briefing Call: New SEC Rule Set on Financial Professional Standard of Conduct and Fiduciary Duty, June 7, 2019
- Expense Sharing Agreements, May 13, 2019, FSI Supervision Workshop
- Regulators Are Following the Money: Compensation Received by Advisor Owned Entities & Why it Can be a Problem for IBDs, May 13, 2019, FSI Supervision Workshop
- Basics of Mutual Funds and Other Registered Investment Companies 2019, May 6, 2019, Practising Law Institute
- Fiduciary Investment Advice 2019, April 2, 2019, Practising Law Institute
- Advisers Act Regulatory Series: 2019 First Quarter Update, March 19, 2019
- Planning for a Patchwork of Best Interest Standards – Recent Developments, February 27, 2019
- Dually Registered Broker-Dealers and Advisers — Regulatory, Compliance and Enforcement 2019, February 6, 2019, Practising Law Institute
- Webcast – Advisers Act Regulatory Series: 2018 Fourth Quarter Update, December 6, 2018
- Webcast: Planning for a Patchwork of Best Interest Standards, November 15, 2018
- Financial Services RegTech and Regulatory Compliance Forum 2018, November 12, 2018, Practising Law Institute
- Bank Asset Management and Collective Investment Funds 2018, October 30, 2018, Practising Law Institute
- Broker/Dealer Regulation and Enforcement 2018, October 16, 2018, Practising Law Institute
- Securities Law and Practice 2018: How the SEC Works, October 15, 2018, Practising Law Institute
- Global Investment Funds 2018, September 20, 2018, Practising Law Institute
- Webcast – Advisers Act Regulatory Series: 2018 Third Quarter Update, September 13, 2018
- Fundamentals of Broker-Dealer Regulation 2018, July 23, 2018, Practising Law Institute
- Fundamentals of Investment Adviser Regulation 2018, June 25, 2018, Practising Law Institute
- Regulatory Developments, June 19, 2018, 2018 MMI Legal & Compliance Seminar
- Webcast – Advisers Act Regulatory Series: 2018 Second Quarter Update, May 24, 2018
- Roundtable Discussion: The SEC’s Proposed Fiduciary Duty and Standards of Conduct for Broker-Dealers and Investment Advisers, May 16, 2018
- Roundtable Discussion: The SEC’s Proposed Fiduciary Duty and Standards of Conduct for Broker-Dealers and Investment Advisers, May 15, 2018
- Basics of Mutual Funds and Other Registered Investment Companies 2018, May 14, 2018, Practising Law Institute
- FSI Webcast: The SEC’s Proposed Standard of Conduct Rules and Forms for Broker-Dealers and Investment Advisers, May 10, 2018, Financial Services Institute (FSI)
- Fiduciary Investment Advice 2018, May 10, 2018, Practising Law Institute
- NSCP Webcast: The SEC’s Proposed Standard of Conduct Rules and Forms for Broker-Dealers and Investment Advisers, May 9, 2018, National Society of Compliance Professionals
- Roundtable Discussion: The SEC’s Proposed Fiduciary Duty and Standards of Conduct for Broker-Dealers and Investment Advisers, May 9, 2018
- Webcast: The SEC’s Proposed Fiduciary Duty and Standards of Conduct for Broker-Dealers and Investment Advisers, May 8, 2018
- BISA Webcast: SEC Fiduciary Rule Proposal, April 24, 2018, Bank Insurance and Securities Association
- CCIT Webinar: Litigation Trends Impacting CITs and the Retirement Marketplace, March 21, 2018
- Webcast: SEC’s Share Class Selection Disclosure Initiative, March 6, 2018, Financial Services Institute
- Webcast – Advisers Act Regulatory Series: 2018 First Quarter Update, February 15, 2018
- Broker-Dealer Retail Wealth Management 2018: Current Legal and Compliance Issues Facing Dual Registrants, February 7, 2018, Practising Law Institute
- Webcast – Advisers Act Regulatory Series: Fourth Quarter Update, December 7, 2017
- Financial Services Industry Regulatory Compliance & Ethics Forum 2017, November 8, 2017, Practising Law Institute
- Securities Law and Practice 2017: How the SEC Works, October 27, 2017, Practising Law Institute
- Webcast – Advisers Act Regulatory Series: Third Quarter Update, September 14, 2017
- Fundamentals of Broker-Dealer Regulation 2017, July 17, 2017, Practising Law Institute
- Fundamentals of Investment Adviser Regulation 2017, June 26, 2017, Practising Law Institute
- Webcast: OBAs: Current Regulatory Issues Concerning Outside Business Activities, June 15, 2017, RegEd
- Webcast: OMG! OBAs: Current Regulatory Issues Concerning Outside Business Activities, May 11, 2017, Financial Services Institute
- Chapter 10: Broker-Dealer Standard of Care, May 2017, Fundamentals of Broker-Dealer Regulation
- Webcast – Advisers Act Regulatory Series: Second Quarter Update, April 27, 2017
- Basics of Mutual Funds and Other Registered Investment Companies 2017, April 20, 2017, Practising Law Institute
- Broker-Dealer Retail Wealth Management 2017: Current Legal and Compliance Issues Facing Dual Registrants, February 8, 2017, Practising Law Institute
- Webcast: Advisers Act Regulatory Developments: A Look at the Year Ahead, January 26, 2017
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of Financial Services Regulation: Broker Dealer (2022-2025)
- Recognized by The Legal 500 United States in the area of financial services: regulatory (2015- 2019, 2022); financial services regulation: broker-dealers (2023) and financial services regulation: banking (2025)
- Recognized by The Legal 500 United States as a "Leading Partner" in the area of financial services regulation: banking (2025)
- Recipient of the SEC’s Manual F. Cohen award for outstanding legal ability
Editor, Practising Law Institute’s Blog, BD/IA: Regulation in Focus
Editor, Practising Law Institute’s Treatise on Broker-Dealer Regulation
Editor, Practising Law Institute’s Treatise on Investment Adviser Regulation
Former Faculty, University of Pennsylvania School of Law, course on investment management regulation
Former Faculty, FINRA Compliance Institute at The Wharton School of the University of Pennsylvania
Former Chair, FINRA Variable Products Committee
- District of Columbia
- New Jersey
- New York
- J.D., Hofstra University School of Law
- B.S., Cornell University