Larry E. Bergmann

Of Counsel

T 202.661.7032 Washington, D.C.
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Larry's practice focuses on complex regulatory matters, with a focus on trading and underwriting issues, short sale regulation, broker-dealer compliance, securities analysts, issuer repurchases, and transfer agents. A longtime lawyer in the Securities and Exchange Commission's Division of Trading and Markets, he also advises on enforcement-related matters.

In his 30 years at the SEC, Larry rose to become the agency's senior associate director for trading practices and processing in the Division of Market Regulation (now the Division of Trading and Markets), where his responsibilities included administering the SEC's trading practices rules, rules applying to short sales, the activities of research analysts, and issuer repurchases. He previously served as assistant director for trading practices in that division and as a branch chief in the Division of Enforcement.

Larry received multiple distinctions at the SEC, including the agency's highest honor, the Distinguished Service Award. He participated in a variety of SEC task forces, and co-chaired task forces on soft dollars (use of client brokerage commissions by fiduciaries to purchase products and services) and the rewriting of the SEC's rules of administrative practice.

Larry served as a board member and chair of the Regulatory Oversight Committee of Direct Edge Exchange and serves as a volunteer at the Jefferson Library of the Thomas Jefferson Foundation in Charlottesville, Virginia.

Practice Highlights

Developing regulations and oversight programs

At the SEC, Larry was responsible for the development and administration of Regulation M, Regulation SHO, and the SEC's interpretive guidance on Section 28(e) of the Securities Exchange Act of 1934. Additionally, he supervised the SEC's oversight program for clearing agencies and transfer agents, the Automation Review Policy program, and the Division of Market Regulation's Enforcement Liaison Office.

Fintech & blockchain

Larry advises clients on regulatory matters related to blockchain and cryptocurrency assets.

International securities organizations

Larry represented the SEC on Standing Committee 2 (Secondary Markets) of the International Organization of Securities Commissions. In that role, he made substantial contributions to numerous published reports. In 2005, he participated in the International Monetary Fund's mission to assess the financial infrastructure of Spain, with a focus on its securities clearance and settlement system.