The U.S. Securities and Exchange Commission’s Division of Enforcement

U.S. Securities and Exchange Commission pic
U.S. Securities and Exchange Commission

A lawyer who has focused for many years on securities investigations and cases, Sylvia Scott is a partner in the Los Angeles-based law firm of Freeman, Freeman & Smiley, LLP. Sylvia Scott also spent 6 years as an attorney with the U.S. Securities and Exchange Commission (SEC), where she concluded her tenure there as an assistant director.

The SEC encompasses several divisions, including the Division of Enforcement that was created to bring together the enforcement activities of all SEC divisions. The SEC performs independent investigations and recommends prosecution in the federal courts regarding any violations of the federal securities laws.

The Division of Enforcement began in 1972 and seeks injunctions with civil suits, prohibiting violators from continuing the actions that are thought to be in violation of the federal securities laws. The Commission has the ability to use several different administrative proceedings, including cease and desist orders, as well as revocation or suspension of business registration, to achieve its objectives.


The Empirical Research Group at UCLA

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University of California, Los Angeles


Sylvia Scott is a lawyer and partner with Freeman, Freeman & Smiley, LLP, focusing her work as an attorney on securities regulations. An alumna of Loyola Marymount University, attorney Sylvia Scott earned her JD from the University of California, Los Angeles, School of Law (UCLA Law).

Recognized as a trailblazer in legal education and training, UCLA Law created the Empirical Research Group (ERG) in the 1990s. ERG focuses on designing and implementing quantitative research in public policy and law.

Faculty members associated with the methodology-oriented group have written extensively on a wide range of topics, encompassing campaign finance disclosure, gay rights, pollution prevention, legal aid, and bankruptcy.

ERG students can select a topic of their choice to improve their skills in data analysis, research design, and statistics. Students involved in the ERG program also have the opportunity to take part in special courses such as public interest law, housing issues, and bankruptcy law along with having the chance to work with prominent researchers in a work study program.

Avoiding Compliance Surprises in Risk-Based FINRA Cycle Exams


National Society of Compliance Professionals (NSCP) Image:
National Society of Compliance Professionals (NSCP)

As head of the Securities Practice Group at Freeman, Freeman and Smiley, LLP, attorney Sylvia Scott has also served on the National Society of Compliance Professionals (NSCP) faculty. In her work as attorney, Sylvia Scott has extensive experience with securities regulation and litigation from the perspective of brokers.

In a 2013 article for NSCP Currents, Ms. Scott provided advice to members of the broker-dealer community in preparing for SEC and Financial Industry Regulatory Authority (FINRA) exams. Particularly challenging are FINRA cycle exams that employ a risk-based approach that has taken the place of previous “one-size-fits-all” strategies.

Although this approach has been in place for a number of years, businesses of all sizes are often caught flat-footed when they find themselves subject to enforcement investigations. Companies are advised to plan well in advance for the eventuality of a FINRA exam and take steps to prevent adverse outcomes. This begins with playing “devil’s advocate” and identifying weak spots that need to be corrected.

Tackling the “Low Hanging Fruit” in Achieving FINRA Compliance

Sylvia Scott, Attorney pic
Sylvia Scott, Attorney

Sylvia Scott is an attorney with the Los Angeles-based corporate law firm Freeman, Freeman and Smiley, LLP, and leads the Securities Practice Group. Attorney Sylvia Scott emphasizes the importance of businesses large and small taking a proactive role in evaluating their internal compliance functions, in ways that correspond with FINRA risk-based criterion for cycle exams.

Assessments can be complex and time consuming, with their true value only emerging when FINRA exams occur. That said, there are a number of “low hanging fruit” targets on which examiners will focus. This reflects a tendency on the part of FINRA investigators to focus on rule violations that are simple to identify and easy to prove.

Easily remediable violations include creating comprehensive and up-to-date written supervisory procedures. This involves the formalizing of practices that may already exist informally, particularly among small companies. Another aspect of this centers on Form U4s, which fully disclose recent activities such as creditor settlements and bankruptcies. It pays to carefully review U4 update requirements, as some aspects of reporting are counterintuitive. Finally, new account forms and applications should be properly filled out and update, as failure to do so is considered a significant regulatory breach.

University of California, Los Angeles Hosts Sixth Annual Tax Symposium

University of California, Los Angeles pic
University of California, Los Angeles

A securities regulation and litigation lawyer with over 30 years of legal experience, Sylvia Scott serves as an attorney and partner at the California-based Freeman, Freeman & Smiley, LLP and manages its Securities Regulation Practice Group. Sylvia Scott received her juris doctor from the University of California, Los Angeles School of Law (UCLA Law), which hosts a variety of events that include the Sixth Annual NYU/UCLA Tax Policy Symposium.

The annual Tax Symposium focuses on tax policy issues from a legal and economic perspective and establishes a forum for policymakers, scholars, and practitioners to perform analyzations and consider reform options. Hosted in conjunction with the New York University of Law (NYU Law), the conference builds on the symposia traditionally presented by NYU Law’s tax policy scholarship law journal and the UCLA Colloquium on Tax Policy and Public Finance.

UCLA Law students, faculty, staff and invited guests may participate in the Sixth Annual Tax Symposium, which will focus on the theme of tax policy and social mobility. Participants may also take part in minimum continuing legal education credit opportunities approved by the California State Bar. The symposium will take place on October 7, 2016 and will receive co-sponsoring by the NYU School of Law and the UCLA Law’s Lowell Milken Institute for Business Law and Policy.

The Culture of Compliance and FINRA

Financial Industry Regulatory Authority pic
Financial Industry Regulatory Authority

Sylvia Scott is an attorney and partner at the Los Angeles law firm Freeman, Freeman & Smiley, LLP. Named a Super Lawyer in multiple years, Sylvia Scott has also authored articles for legal journals on topics related to compliance with FINRA regulations in conjunction with her role as an attorney.

Each year, FINRA releases its Annual Regulatory and Examination Priorities Letter in order to disseminate information among businesses about important issues as they relate to compliance with FINRA’s regulatory programs. In 2016, one of the main emphases of FINRA’s letter was a stringent focus on firm culture. FINRA asserted that it would put focus on determining if examined firms supported a “culture of compliance.”

In order to facilitate a culture of compliance, businesses are expected to exhibit a commitment to five core facets of operations. These operations encompass such issues as whether or not employees abide by control functions, whether leaders tolerate the violation of control breaches, and how much effort a company puts into seeking out instances of risk and compliance. Additionally, employees in positions of power must display a strong commitment to a compliant firm culture for the benefit of their teams. Sub-cultures within the corporate structure must also be monitored to make sure that operations fall under direct conformity with the company’s overall commitment to compliance.

BTI Power Rankings Reveal Law Firms with the Best Client Relationships

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BTI Power Rankings

Freeman, Freeman & Smiley, LLP attorney and partner and lawyer Sylvia Scott leads the firm’s Securities Regulation Practice Group and maintains a reputation of successfully representing clients in a variety of securities regulation and litigation cases. Sylvia Scott’s firm also received recognition from the BTI Power Rankings 2016: The Law Firms with the Best Client Relationships, for which it landed in the top five percent in the financial services industry.

The BTI Power Rankings provides recognition to firms that place the client first and go above and beyond to form strong bonds with their clients. It analyzes direct feedback from corporate counsel and examines the strength of firm-client relationships in 16 industries using in-depth interviews. Relationship strengths are measured through three criteria; which businesses clients name as their go-to companies, which firms clients most recommend to peers, and which firms receive both recommendations and commendations from clients.

The final criteria falls under a BTI classification known as Clientopia, which the organization considers the ideal state of a client relationship. Law firms that reach the Clientopia level continue to win work from existing clients while simultaneously earning the respect of new ones. Therefore, a strong client relationship gives the firm a competitive edge and serves as a market differentiator.

Studies conducted in order to identify and rank companies on the BTI Power Rankings use independent funding and rely completely on interviews with C-level executives and service leaders, such as general counsel, chief audit officers, and chief financial officers.

To learn more about the BTI Power Rankings, visit