Eden L. Rohrer, Partner New York
Phone: +1 212.803.4063
590 Madison Avenue, 20th Floor
New York, NY 10022-2544

Eden Rohrer is a partner in the Corporate, Financial Services, and White Collar and Regulatory Enforcement groups in Crowell & Moring's New York office. She concentrates her practice in broker-­dealer regulatory, compliance, enforcement, litigation, and arbitration matters.

Eden assists broker-­dealers and their associated persons to respond to regulatory examinations and inquiries and provides effective representation in a range of enforcement proceedings with the SEC, FINRA, state and foreign regulatory authorities. She regularly prepares and defends witnesses in FINRA on-the-record interviews and SEC testimony. Enforcement matters have involved issues including market manipulation, insider trading, anti-money laundering, distribution of unregistered securities, net capital requirements, market making, Rule 15c2­11, Regulation M, soft dollar arrangements, cross border trading, electronic intrusion and customer impersonation, sales practices, supervision, private placements in both privately held and publicly traded securities (PIPEs), credit default swaps, futures, options, fixed income, indexes, and other securities products.

Eden's practice involves all aspects of broker-dealer regulation, including Self Regulatory Organization (SRO) membership, employment, research, soft dollar arrangements, chaperoning of foreign broker-dealers, social media, Regulation M, anti­money laundering rules, and market making issues. She also provides regulatory guidance to investment banking clients in connection with securities offerings and related trading issues.  

Eden advises firms in the FINRA new membership (NMA) and the continuing membership (CMA) process. She assists firms to develop or amend their written supervisory procedures and compliance manuals. She has assisted several clients to develop and obtain regulatory approval for electronic trading platforms and alternative trading systems.   

In addition, Eden has extensive experience in FINRA and AAA arbitrations and state and federal litigation involving a broad range of securities and corporate issues. She has represented broker-­dealers in industry disputes as well as defended variety of customer claims concerning allegations of fraud, forgery, unsuitability, churning, misappropriation, improper use of margin, breach of fiduciary duty, failure to supervise, failure to execute, unauthorized trading, breach of contract, misrepresentations, and omissions and violations of state and federal securities laws. Her experience includes cases involving IPOs, stocks, options, bonds, limited partnerships, private placements, annuities, mutual funds, and other products.

Eden regularly addresses questions with respect to what activities require or are exempt from broker­-dealer registration. She assists firms in obtaining guidance, interpretive letters, and no-action relief from FINRA and the SEC with respect to novel securities issues and the creation of new products and services. Eden is a leader in the M&A Broker space as one of the six lawyers who crafted and obtained a No-Action Letter from the Securities and Exchange Commission (SEC)—the M&A Brokers Letter. Also known as the "Six-Lawyers Letter," it allows M&A brokers to receive transaction-based compensation without registering as brokers with the SEC. Eden regularly counsels M&A Broker clients. 

Eden is the vice-chair of the American Bar Association's Task Force on Private Placement Broker-Dealers. She is also the co-facilitator for the Midtown Regulatory Group, a group of over 800 senior compliance and legal officers from brokerage firms located throughout the U.S. that meets monthly to discuss regulatory issues.

Selected Client Representations

  • Represented broker-dealer and two individuals in FINRA enforcement matter involving AML and books and records violations in connection with offshore trading from the FINRA routine examination, through the Wells process, mediation, and preparation for hearing. Settled matter by obtaining full withdrawal of complaint against one principal and settlement against the firm and remaining principal shortly before hearing. 
  • Obtained FINRA membership approval for various clients including fixed income ATS, electronic trading platform, fixed income trading firm, and private placement broker-dealer.
  • Assisted dual-registered broker-dealer and investment advisor to restructure operations to create two separate regulated entities.
  • Represented broker-dealer in SEC and FINRA insider trading investigation resulting in no charges being brought against the firm or individuals.
  • Represented broker-­dealer in successful motion to dismiss in New York State Court alleging claims of unconscionability, unjust enrichment and unilateral mistake seeking rescission of a securities transaction in which client acted as a market maker.
  • Represented broker in action by investor in private placement alleging fraud, obtaining dismissal of all claims upon conclusion of claimant's case and obtaining expungement of broker's CRD record.
  • Represented broker-­dealer and market making firm claimant in arbitration against respondent clearing firm for fraud and obtained award assessing liability against clearing firm acting on behalf of its customer after five day hearing.
  • Represented broker-dealer in claim against former trader for recovery of trading losses in arbitration that included allegations of fraud resulting in award after several days of hearings.


Admitted to practice: New York, U.S. District Court for the Eastern District of New York, U.S. District Court for the Southern District of New York 

American Bar Association
Securities Industry and Financial Markets Association, Legal and Compliance Division
Midtown Regulatory Group

Judicial Clerkships
Student law clerk to Justice Harold Baer, Supreme Court of the State of New York, Summer 1988

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Client Alerts & Newsletters

In the News

  • Some Expect to See SEC Lean Away from Courts Following Judge's Criticism
    January 16, 2012 — Broker Dealer (BD) Week

Firm News & Announcements

Oct.08.2014 Crowell & Moring's Linda Lerner and Eden Rohrer Co-Author Bloomberg BNA Portfolio on Broker-Dealer Registration
Jan.04.2012 Crowell & Moring Boosts New York Office with Addition of Two Broker-Dealer Partners
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