Mr. Pickard is the senior founding partner of Pickard Djinis and Pisarri LLP. Mr. Pickard advises financial services firms with regard to a range of issues, including those involving market structure, financial responsibility rules, soft-dollars and investment company regulatory reform.
Experience in Government
From 1973 to 1977, Mr. Pickard was Director of the Division of Trading and Markets of the SEC, which Division has responsibility for the regulation of broker-dealers, underwriters, municipal securities firms, banks insofar as they engage in securities activities, and other financial institutions, and the oversight of stock exchanges and FINRA.
Leading issues and topics addressed during Mr. Pickard’s tenure as Director of the Division of Trading and Markets included:
- The deregulation of fixed commission rates on exchanges
- The revamping of financial responsibility rules for broker-dealers and stock exchanges (e.g., the net capital rule, the segregation, reserve rule and the creation of SIPC)
- The formulation and regulation of liquid options markets; the development of integrated securities markets with accompanying requirements regarding trade reporting, quotations dissemination, market access provisions and market participation qualifications
- The development of a central depository for stock certificates – a modern system of clearance and settlement of securities transactions, the regulation of transfer agents, and the immobilization of the stock certificate
- Oversight by the SEC of exchanges
- The NASD (now, FINRA) and the MSRB in regard to their rulemaking and disciplinary processes
- Steps to improve the regulation of short selling and insider trading; and
- Reformulation of regulations relating to recordkeeping, the securities transaction confirmation process and other disclosures of securities transactions.
Mr. Pickard was a principal contributor to several of the SEC’s studies and participated in the formulation of legislative proposals leading up to the Securities Acts Amendments of 1975, the most comprehensive revision of the Securities Exchange Act of 1934 since its passage. He served as a member of the SEC’s National Advisory Committee on the Implementation of a Central Market System.
From 1971 to 1973, Mr. Pickard served as Special Counsel to the Chairman of the Securities and Exchange Commission.
Mr. Pickard assisted in the establishment of a stock exchange in Kuwait under the sponsorship of the Central Bank of Kuwait.
He was a participant and speaker at the Regional Regulators Workshop sponsored by the Securities Commission of Malaysia in January 1995, and a keynote speaker at the Conference on Development and Integration of Financial Markets in the Caribbean Region in Jamaica in December 1995, sponsored in part by the Organization of American States.
Mr. Pickard has served as a faculty member of the International Law Institute, Washington, D.C.
Mr. Pickard has testified before numerous Congressional Committees and addressed business and public groups concerning securities industry matters and SEC regulatory programs and policies.
He has lectured before the American Bar Association-American Law Institute, the Practising Law Institute, the Securities Regulation Institute, the Federal Bar Association, the International Law Institute and other securities regulation and law groups.
He has published a number of articles on securities law and regulation in the Business Lawyer, Legal Times and other journals and has served as chairman of several Practising Law Institute and Prentice-Hall securities programs.
Mr. Pickard has served as an adjunct professor at American University School of Law, teaching a senior seminar in securities markets and regulation.
Bar and Securities Industry Memberships
New York State; District of Columbia
American Bar Association – Committee on Federal Regulation of Securities
Former member of the Subcommittee on Market Regulation
American Bar Association – Committee on Business Law
Former member of the Subcommittee on Securities Activities
Nasdaq Stock Market, Inc.
Former member of the Market Operations Review Committee (1996-2000)
The Harvard Law School, LL.B., 1963
Colgate University, A.B., 1960 (Phi Beta Kappa)
Most US Money Managers Not Subject to MiFID II & May Continue to Use Soft Dollars, Integrity Research Associates (July 17, 2017).
Risky SEC Exemption Requires More Scrutiny, American Banker (October 16, 2012)
SEC’s Old Capital Approach was Tried-And True, Viewpoints, American Banker (August 8, 2008)
Institutional Participation In the OTC Market: Payment Of Commissions And Other Compensation On OTC Transactions, Industry Viewpoint, Traders Magazine (November 2001).
House Version of Trust Bill Goes Too Far, Viewpoint, American Banker (July 9, 1999).
New SEC Inspection Program, Practising Law Institute (June 1997).
SEC Examines Soft Dollar Practices and Compliance by Investment Advisers, INSIGHTS – The Corporate & Securities Law Advisors (March 1997).
New Disclosure Requirements Imposed By SEC On Payment For Order Flow Practices, Review Of Securities And Commodities Regulation (Standard & Poor’s) (1996).
The State of Soft Dollars, Industry Viewpoint, Traders Magazine (February 1996).
Money Managers, Mutual Funds And Their Service Providers, Dealing With Regulatory Developments, Practising Law Institute (March 1995).
A Fiduciary’s Guide To Federal Securities Laws, American Bar Association (1994).
Supervisory And Compliance Update, Prentice Hall Law & Business (1991)
Securities Portfolio Executions: Transaction-Based Compensation Soft Dollar Practices, PLI (1991).
Institutional Portfolio Execution: Soft Dollar Arrangements, INSIGHTS – – The Corporate & Securities Law Adviser (August 1990).
Trading Practices, The Portfolio Execution Process and Soft Dollar Practices, PLI (1990).
The Applicability Of The Short Sale Rule To Modern Trading Strategies, INSIGHTS (June 1990).
Trading Practices, The Portfolio Execution Process and Soft Dollar Arrangements, PLI (1989).
Frontrunning, Regulators Mount New Attack On Inter-Market Abuses, INSIGHTS (October 1989).
NASD Disciplinary Proceedings: Practice and Procedures, The Business Lawyer (April 1982).
Working Guide For Understanding And Determining Net Capital Requirements of Broker-Dealers, Bond Buyer (1979).