COMPLIANCE CONSULTING AGREEMENT
Exhibit
(h)(9)
THIS AGREEMENT (the "Agreement") is to be effective as of the 1st day
of January, 2009, by and between Xxxxxx Financial
Consulting, LLC, a
Pennsylvania limited liability company ("HFC"), and Xxxxxxx Capital Mutual Funds, a
Delaware Statutory Trust (the "Trust]").
WHEREAS, HFC is a compliance consulting firm
specializing in providing regulatory compliance products and services to, among
others, SEC registered investment companies;
WHEREAS, the Trust is an SEC registered
open-end management investment company of the series type and offers shares of
one distinct series, the Xxxxxxx Capital Mid Cap Fund ("Fund") to the public;
WHEREAS, the Trust is subject to a number of
regulatory requirements under various federal and state laws, including among
others, Rule 38a-1 under the Investment Company Act of 1940, as amended (the
"1940 Act"); and
WHEREAS, the Trust desires to engage HFC to
provide certain ongoing regulatory compliance consulting, monitoring and
reporting services, all such services designed to satisfy the Trust's
obligations under Rule 38a-1 and HFC is willing to provide those services upon
the terms and conditions set forth in this Agreement;
NOW THEREFORE, for and in consideration
of the mutual agreements and covenants contained herein, HFC and the Trust
hereby agree as follows:
1.
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ENGAGEMENT OF HFC AND DESIGNATION
OF CHIEF COMPLIANCE OFFICER
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The Trust hereby engages HFC to provide
the ongoing regulatory compliance consulting, monitoring and reporting services
described in Schedule
A to this Agreement, and
HFC hereby accepts such appointment. Schedule
A is incorporated into and
made a part of this Agreement and may be amended from time to time by mutual
written consent of the parties.
The Trust appoints Xxxxxxx X.
Xxxxxx, Esq., an officer of
HFC, as its designated Chief Compliance Officer (the "CCO") as required under Rule 38a-1 under the
1940 Act. Xx. Xxxxxx, on behalf of HFC, accepts such appointment under the terms
and conditions set forth in this Agreement. Xx. Xxxxxx shall serve as the
Trust's designated CCO until such time as his successor shall be duly qualified
and appointed by the Trust. HFC shall immediately inform the Trust of any matter
that would or might have a materially negative effect on a currently designated
CCO's ability to properly serve the Trust. In the event that Xx. Xxxxxx shall
become unable or unwilling to continue serving as the Trust's designated CCO,
HFC shall immediately provide the Trust with a suitable officer candidate to
replace the CCO or shall terminate this Agreement in accordance with its terms.
In the event that HFC is unable to provide an individual that the Board of the
Trust in its sole discretion believes is appropriate and suitable to serve as
the designated CCO acceptable to the Trust, the Trust may immediately terminate
this Agreement without penalty. Xx. Xxxxxx’x biography is attached as
Schedule
C to this
Agreement.
2.
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COMPENSATION
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The Trust agrees to pay for the services
to be provided by HFC as set forth in Schedule
A to this Agreement in
accordance with, and in the manner set forth in Schedule
B to this Agreement.
Schedule
B is incorporated into and
made a part of this Agreement and may be amended from time to time by mutual
written consent of the parties.
If the Board decides to increase the
CCO’s compensation or provide a bonus to the CCO, then either the fees paid to
HFC by the Trust will increase proportionately or the Trust will separately
compensate the CCO for any amounts it deems due to the CCO above the amounts due
to HFC under this agreement. Otherwise, the board may directly increase the fees
paid to HFC via an amendment to this Agreement. Any attempt by the Board to
reduce the salary of the CCO would be contrary to the terms of this
Agreement.
If this Agreement becomes effective
subsequent to the first day of a month, HFC’s compensation for that part of the
month in which the Agreement is in effect shall be prorated in a manner
consistent with the calculation of fees as set forth in Schedule
B, and shall be due and
payable as of the effective date of this Agreement.
3.
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REIMBURSEMENT OF
EXPENSES
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In addition to paying HFC the fees
described in Schedule
B to this Agreement, the
Trust agrees to reimburse HFC for the reasonable out-of-pocket expenses
described in Schedule
B.
4.
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INDEPENDENT
CONTRACTOR
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HFC shall act as an independent
contractor and not as an agent of the Trust and HFC shall make no representation
as an agent of the Trust, except that the CCO as appointed by the Trust’s board
shall be empowered with full responsibility and authority to develop and enforce
appropriate policies and procedures for the Trust.
HFC does not offer legal or accounting
services and does not purport to replace the services provided by legal counsel
or that of a certified public accountant. If contracts are provided, they will
be forms only and the provision of such contracts does not constitute and should
not be deemed to be legal advice. The representatives of HFC are experts, and as
such will make every reasonable effort to provide the services described in this
Agreement. However, there is no guarantee that the work performed by HFC will be
favorably received by any regulatory agency.
WITHOUT LIMITING THE GENERAL
APPLICABILITY OF THE PRECEDING PARAGRAPH, THE TRUST EXPRESSLY ACKNOWLEDGES AND
AGREES THAT SERVICES TO BE PROVIDED BY HFC UNDER THIS AGREEMENT ARE NOT LEGAL
SERVICES AND THAT THIS AGREEMENT DOES NOT CONSTITUTE AN ATTORNEY-CLIENT
RELATIONSHIP BETWEEN HFC AND THE TRUST. THE TRUST ALSO
EXPRESSLY ACKNOWLEDGES AND AGREES THAT THE SERVICES TO BE PROVIDED BY HFC UNDER
THIS AGREEMENT, AND ANY COMMUNICATIONS BETWEEN HFC AND THE TRUST RELATING TO
SUCH SERVICES, ARE NOT PROTECTED UNDER ANY CLAIMS OF LEGAL PRIVILEGE OR ATTORNEY
WORK PRODUCT.
Although HFC’s work may involve analysis
of accounting and financial records, at no time will work performed by HFC be
deemed to be an audit of the Trust in accordance with generally accepted
auditing standards or otherwise.
5.
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STANDARD OF CARE, LIMITATION OF
LIABIILTY AND
INDEMNIFICATION
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(a)
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Limitation of
Liability. HFC shall
not be liable for and the Trust shall hold HFC harmless in regard to any
liability incurred for any action reasonably taken by HFC or failure to
act by HFC in reliance upon:
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(i)
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information, records and reports
generated by the Trust;
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(ii)
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advice of the Trust, or of counsel
for the Trust;
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(iii)
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statements of the
Trust’s independent
accountants;
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(iv)
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Any written instruction or
certified copy of any resolution of the Board; or
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(v)
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Any signature, instruction,
request, letter of transmittal, certificate, opinion of counsel,
statement, instrument, report, notice, consent, order, or other document
reasonably believed in good faith by HFC to be genuine and to have been
signed or presented
by the Trust or other proper party or
parties.
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provided that such action or failure to
act is not, to the knowledge of HFC, in violation of applicable federal or state
laws or regulation, and provided further that such action or failure to act is
made without gross
negligence, bad faith, willful misconduct or reckless disregard of its duties.
The Trust shall hold HFC harmless in regard to any liability incurred by reason
of the inaccuracy of such information provided by the Trust or for any action
reasonably taken or omitted in good faith
reliance on such information.
(b) Reliance. HFC may rely upon the genuineness of any
document, copy or facsimile thereof reasonably believed in good faith by HFC to
have been validly executed and HFC shall not be under any duty or obligation to inquire into
the validity or invalidity or authority or lack of authority of any statement,
oral or written instruction, resolution, signature, request, letter of
transmittal, opinion of counsel, instrument, report, notice, consent, order or any other document or
instrument which HFC reasonably believes in good faith to be
genuine.
(c) Errors of
Others. HFC shall not be
liable for the errors of other Service Providers to the Trust and errors in
information provided by an investment adviser or custodian of the Trust;
except or unless any HFC action or inaction is a direct or proximate cause of
the error.
(d) Indemnification of
HFC. The Trust shall
indemnify and hold HFC harmless from and against any and all losses, damages,
costs, charges, reasonable counsel fees, payments, expenses and liability
arising out of or attributable to the Trust’s refusal or failure to comply with
the terms of this Agreement, or which arise out of the Company’s/Trust’s lack of
good faith, gross negligence or willful misconduct with respect to the Trust’s
performance under or in connection with this Agreement.
(e) Indemnification of
the Trust. HFC shall
indemnify and hold the Trust harmless from and against any and all losses,
damages, costs, charges, reasonable counsel fees, payments, expenses and
liability arising out of or attributable to HFC’s refusal or failure to comply
with the terms of this Agreement, or which arise out of HFC’s lack of good
faith, gross negligence or willful misconduct with respect to HFC’s performance
under or in connection with this Agreement.
(f) Limitation of
Shareholder and Board Liability. The Trustees of the Trust and the
shareholders of the Funds shall not be liable for any obligations of the Trust
under this Agreement and HFC agrees that, in asserting any rights or claims
under this Agreement, it shall look only to the assets and property of the Trust
to which HFC’s rights or claims relate in settlement of such rights or claims
and not to the Trustees or the shareholders.
(g) In the event that HFC is requested,
pursuant to subpoena or other legal process, to provide testimony or produce its
documents relating to its engagement under this Agreement, in judicial or
administrative proceedings to which HFC is not a party, HFC shall promptly
notify the Trust and shall be reimbursed by the Trust at standard billing rates
for HFC’s professional time and expenses, including reasonable attorneys fees
incurred in responding to such request.
(h) Notwithstanding the indemnification
provisions above, to the extent that the CCO incurs any liability in connection
with the performance of his duties under this Agreement, he shall be covered
under the Directors and Officers Errors and Omissions insurance policy of the
Trust, in accordance with the terms therein. If such policy is utilized on the
CCO’s behalf, none of the deductable will be payable by HFC.
6.
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CONDITIONS
PRECEDENT
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The following condition must be met
within a reasonable amount of time following the execution of this
agreement:
The Trust will obtain a written
representation from the provider of Directors and Officers/Errors and Omissions
Insurance coverage for the Trustees and officers of the Trust, to the effect
that the Trust’s CCO is fully covered thereunder as an officer of the
Trust.
7.
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INFORMATION FURNISHED BY THE
PARTIES DUTY OF CO-OPERATION
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(a) In order for HFC to properly serve the
Trust and its shareholders, the Trust agrees to provide HFC any information HFC
may reasonably request in furtherance of HFC obligations under this Agreement. The
Trust must notify HFC immediately of any changes that have or may have a
material impact on Trust business, its operations, or its personnel. The Trust
must also immediately notify HFC of any changes with respect to the
Trust’s registration status with the SEC, any
audit, enforcement, or regulatory actions commenced against the Trust by any
regulatory authority, and any compliant, grievance or action threatened or
commenced against the Trust by any shareholder.
(b) The Trust also agrees to cooperate fully with HFC and
provide in a timely manner any information concerning the Trust and its
affiliates reasonably required by HFC insofar as such information relates to any
policy, procedure, contract or other matter subject to HFC ongoing services as set forth in Schedule
A to this
Agreement.
(c) The Trust further agrees to authorize
and direct the Trust’s investment adviser, transfer agent,
fund accounting agent, and administrator to cooperate fully with HFC and provide
in a timely manner any
reasonable request for information from HFC insofar as such information relates
to any policy, procedure, contract or other matter subject to HFC ongoing
services as set forth in Schedule
A to this
Agreement
(d) In order for HFC to properly serve the
Trust and its shareholders,
HFC agrees to provide to the Trust any information the Trust may reasonably
request in furtherance of HFC obligations under this Agreement. HFC will notify
the Trust immediately of any changes that have or may have a material
impact on HFC business, its operations, or its
personnel, or HFC ability to provide the services called for under this
Agreement.
8.
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RECORD RETENTION AND
CONFIDENTIALITY
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HFC shall keep and maintain copies of
all books and records which the Trust is, or may be required to keep and
maintain pursuant to any applicable statutes, rules and regulations, and which
relate to the products and/or services to be provided by HFC under this
Agreement. HFC expressly acknowledges and agrees that all such books and records
are to be maintained with the utmost privacy and confidentiality, and HFC shall
keep confidential all books, records, documents and other information, whether
created by HFC or provided to HFC by the Trust, unless compelled to produce any
of them by duly-constituted authorities or legal process. HFC further agrees to
maintain adequate data backup facilities and emergency plans and procedures
reasonably designed to safeguard the Trust’s books and records from permanent
loss.
HFC further agrees to maintain as
confidential any non-public personal information (as defined by Regulation S-P
under the Federal Securities Laws) of any shareholder of the Trust and to use
such information solely for the purposes of this Agreement.
HFC and the CCO agree to promptly notify
the Trust of any request for records or any subpoena by any governmental agency
or third party. In the event that HFC or the CCO is requested by
legal process to disclose Confidential Information, HFC shall notify the Trust
therefore and shall cooperate with the Trust and the Boards, as appropriate, at
the expense of the Trust or the Board, as appropriate, in any action that such
entity may desire to take to protect its Confidential
Information.
9.
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TERM AND
TERMINATION
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This Agreement shall continue in full
force and effect until terminated. The Trust may terminate this Agreement
without penalty upon thirty (30) days prior written notice to HFC, and HFC may
terminate this Agreement without penalty upon ninety (90) days written notice to
Trust.
If this Agreement terminates prior to
the last day of a month, HFC compensation for that part of the month in which
the Agreement was in effect shall be prorated in a manner consistent with the
calculation of fees as set forth in Schedule
B, and if prepaid, an
appropriate refund shall be promptly made.
If the CCO voluntarily resigns, at the
discretion of both parties, HFC may present an alternative CCO for Board
consideration and approval to continue CCO duties under this Agreement. If the
Board chooses to end its relationship with HFC as a result of such voluntary
resignation by the CCO, the contract with HFC would end, and the Trust would pay
HFC only for fees and any negotiated Out of Pocket Expenses accrued up to the
point in time when the Board’s new CCO officially resumes responsibility. HFC
will make every effort to assist the Board in a smooth transition during this
period.
HFC shall promptly deliver to the Trust
at the termination of this Agreement, or at any time upon the Trust’s request,
all books, records, documents and other information relating to the Trust or its
Affiliates retained pursuant to Section 8 of this Agreement that HFC or the CCO
may then possess or have under its control regardless of the location or form of
such material. Further, if requested by the Trust, HFC will provide
the Trust with written confirmation that all such materials have been delivered
to the Trust.
10.
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MISCELLANEOUS
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(a) Non-Exclusivity. This Agreement is not exclusive, and
the Trust expressly acknowledges and agrees that HFC may provide services to other
persons that are similar to the services HFC provides to the
Trust.
(b) Entire Agreement.
This Agreement supersedes
any and all other agreements, whether oral or in writing, between the parties
with respect to the subject
matter of this Agreement, and this Agreement contains all of the covenants and
understandings between the parties with respect to said
matters.
(c) No
Assignment. This Agreement
may not be assigned without the express prior written consent of the other
party, which consent may be
withheld for any reason; provided, however that the Trust may assign this
Agreement to any successor
registered management investment company
in furtherance of a merger, reorganization or other corporate
action.
(d) Amendment
of this
Agreement. No provision of
this Agreement may be changed, waived, discharged, or terminated orally, but
only by a written instrument signed by both parties.
(e) Captions. The captions in this Agreement are
included for convenience of reference only and in no way define or limit any of the
provisions hereof or otherwise affect their construction or effect. If any
provision of this Agreement shall be held or made invalid by a court decision,
statute, rule or otherwise, the remainder of the Agreement shall not be affected thereby. This
Agreement shall be binding on, and shall inure to the benefit of the parties
hereto and their respective successors.
(f) Governing
Law. This Agreement shall
be construed in accordance with and governed by the laws of the Commonwealth of Pennsylvania, without
regard to such jurisdiction's conflict-of-law statutes.
(h) Notices. Any notices required under this
Agreement shall be in writing and may be sent by any method reasonably designed
to inform the other party of such notice, including certified mail, overnight
delivery, courier service, facsimile transmission, or
other appropriate means.
(i) Counterparts. This Agreement may be executed in
counterparts by the parties hereto, each of which shall constitute an original,
and all of which together shall constitute one Agreement.
IN WITNESS
WHEREOF, the parties have
entered into this Agreement to be effective as of the day and year first above
written.
XXXXXX FINANCIAL CONSULTING,
LLC
/s/ Xxxxxxx
X. Xxxxxx
By: Xxxxxxx X. Xxxxxx,
Owner
XXXXXXX CAPITAL MUTUAL
FUNDS
/s/ Xxxxxxx
X. Xxxxxx
By: Xxxxxxx X.
Xxxxxx
Title: Chairman of the Board of
Trustees
President
SCHEDULE A
RULE 38A-1 COMPLIANCE
SERVICES
Provide all CCO compliance services
consistent with the requirements of Rule 38a-1, including without
limitation:
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Administer and enforce the
Trust’s Compliance
Program
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Provide general and ongoing
regulatory and compliance consultation, advice and recommendations to the
Board of Trustees (the "Board")
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·
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Provide ongoing review and
oversight of the Trust, Investment Advisory, Sub-advisory,
Transfer Agent, Fund Accounting and Fund Administration compliance
programs to ensure ongoing implementation and
effectiveness
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·
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Establish and maintain interface
plan for oversight of the Trust, Adviser, Sub-adviser, Fund
Accountant, Transfer
Agent and Administrator
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·
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Conduct on-site reviews (including
risk assessments and testing) of the Trust and remote reviews of Service
Provider compliance programs at least annually, and make recommendations
for amendments
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·
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Provide regular quarterly compliance report to the
Board
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·
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Report violations and
recommend remedial actions to the
Trust. In the event that the CCO reports violations and is not
reasonably satisfied with the Trust’s efforts to address and remedy
the same, the CCO shall report such violations to the
Board
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·
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Provide required Rule 38a-1 annual
written report to the Board
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Conduct required Rule 38a-1 annual
meeting with Independent Trustees and be available as needed for in-person
or telephone meetings with the Board and Committee of Independent
Trustees
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·
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Provide compliance support to the
Trust with respect to SEC examinations, inspections and regulatory
issues
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Cooperate with the Trust in
responding to any inspection by or information request from the SEC that
relates to matters
covered by this Agreement
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·
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Cooperate with legal counsel to
the Trust and legal counsel to its Adviser in providing all services under
this Agreement
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Respond to any request from the
Board for additional
information
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Perform quarterly compliance
testing and such
other transactional, periodic and forensic testing as necessary to provide
services hereunder
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·
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Consult with the Board, the Trust
and its representatives as necessary to amend, update and revise the
Compliance Program. Recommend amendments and draft policies and procedures as
they pertain to:
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-
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consistency with regulatory
expectations or risk-based policies and
procedures;
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maintenance of compliance with the
Federal Securities Laws; and
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any other changes as necessary to
ensure the Compliance
Program is reasonably designed to prevent, detect and
promptly remedy violations of the Federal Securities Laws
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SCHEDULE B
FEES
HFC will provide all of the services
described in Schedule A above for a fee of $[redacted] per month, with the
payment for services in January 2009 due upon the execution of this Agreement
and fees for successive months payable in advance thereafter not later than five
(5) days after the first business day of the month in which such services are to
be rendered. Monthly payments are considered late if not received by the
fifteenth day of any month in which such services are to be rendered. HFC will
not be responsible for providing ongoing services to the Trust or for any
liability relating to such services during any month in which HFC fees for such
services are not received by the fifteenth day of the month in which such
services are to be rendered.
OUT-OF-POCKET
EXPENSES
In addition to the above fees, the Trust
agrees to reimburse HFC or pay directly reasonable out-of-pocket expenses
incurred by HFC on the Trust's behalf, including but not limited
to:
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All postage, freight, delivery and
bonding charges (if any) incurred by HFC in delivering materials to the
Trust;
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All expenses incurred in
connection with any
custom programming or systems modifications required to provide any
special reports or services requested by the Trust and approved by the
Trust in advance of their
occurrence;
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Travel expenses approved by the
Trust in advance of their occurrence; and
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Any additional expenses reasonably
incurred by HFC in the performance of its duties and obligations under
this Agreement and approved by the Trust in advance of their
occurrence.
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All reimbursement is subject to
provision of an invoice accompanied by an itemized accounting and written proof
of all expenses. HFC shall pre-clear each out-of-pocket expense before it is
incurred.
SCHEDULE
C
XXXXXXX
X. XXXXXX BIO
XXXXXXX X. XXXXXX,
ESQ.
Xxxxxx
Financial Consulting LLC
0000
Xxxxxx Xxxx, Xxxxx 000
Xxxx,
Xxxxxxxxxxxx 00000
(000)
000-0000
xxxx@xxxxxxxxxx.xxx
EDUCATION:
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GEORGETOWN
UNIVERSITY LAW CENTER, Washington,
D.C.
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LLM,
Federal Securities Regulation, 0000
XXXXXXXXXX
XXXXXXXXXX XXXXXX XX XXX, Xxxxxx,
Xxxxxxxxxx
JD, May
0000
XXXXXXXXXX
XX XXXXXX, Xxxxxx,
Xxxx
BS,
Business Administration, April 1983
Honors/Activities: Honors Program
Graduate
Degree
completed in three years
PROFESSIONAL
EXPERIENCE:
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XXXXXX FINANCIAL
CONSULTING LLC, Mars,
Pennsylvania
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May
2006 to present
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Owner of
independent legal/consulting firm specializing in providing broker-dealer,
investment adviser, hedge fund and mutual fund related legal and compliance,
regulatory professional services. Services include general regulatory
legal support, enforcement defense, chief compliance officer outsourcing,
arbitration, mediation, and expert witness.
Valhalla
Capital Partners, LLC, Louisville, Kentucky - Chief Compliance Officer.
Firm specializes in managing closed-end funds investing primarily in
mortgage-backed securities.
Magnetar
Spectrum Fund,
(2006-2008) Evanston. Illinois – Chief Compliance
Officer. Fund invests primarily in credit and master limited
partnerships.
Pennant
Park Fund, (2006-2008)
New York, NY – Chief Compliance Officer to Business Development
Company.
THE PNC FINANCIAL SERVICES
GROUP, INC., Pittsburgh, Pennsylvania
August
1999 to May 2006
Chief
Broker-Dealer Counsel
J.J.B.
Xxxxxxxx, X.X. Xxxxx – General Counsel to full-service broker-dealer and
registered investment adviser. Responsible for all legal services
including dispute resolution/litigation, regulatory examinations, compliance
oversight and regulatory counseling.
PNC
Investments LLC – General Counsel to introducing
broker-dealer. Member NASD/SIPC. Responsible for all legal
services including dispute resolution/litigation, regulatory examinations,
compliance oversight and regulatory counseling. Also responsible for legal work
related to retail insurance product sales programs.
FEDERATED
INVESTORS, Pittsburgh,
Pennsylvania
June 1996
to August 1999
Corporate
Counsel to multiple mutual funds, separate accounts, and institutional
investment pools. Primary counsel for capital markets, bank
broker-dealer and broker-dealer wholesale functions. Responsible for
mutual fund acquisitions and related legal work, including performing due
diligence, ensuring efficient negotiations, timely SEC filings, and closing
transactions.
BANC ONE
CORPORATION, Columbus,
Ohio
January
1993 to June 1996
Responsible
for legal services related to bank holding company, securities activities
including broker-dealer (retail and Section 20 underwriting affiliates),
investment adviser, investment company, and annuity sales.
Banc One
Securities Corporation – General Counsel and Secretary for retail
broker-dealer registered with SEC and member NASD/SIPC.
Banc One
Investment Advisors Corporation – General Counsel and Secretary for SEC
registered investment adviser to bank proprietary mutual
funds. Responsible for all legal services to
subsidiary.
Banc One
Insurance Services Corporation – General Counsel and Secretary for
bank-owned, insurance agency and life insurance
subsidiary. Responsible for structuring annuities programs in various
states.
UNITED
STATES SECURITIES AND EXCHANGE COMMISSION, San Francisco,
California
Senior
Counsel – San Xxxxxxxxx Xxxxxx Office, Enforcement Division
May 1991
to December 1992
Responsible
for supervising, investigating and litigating enforcement
matters. All performance evaluations
“outstanding.” (Completed National Institute of Trial Advocacy
Training Program: Western Regional Conference, Berkeley,
California)
Staff
Attorney
January
1989 to April 0000
XXXXXX,
XXXXXX & XXXXXXXXX, Xxxxxxxxxx, X.X.
Special
Law Clerk
September
1987 to December 1988
Researched
variety of legal issues for Xxxxxx X. Xxxxxxx (Securities Litigation
Partner). Drafted outlines and legal articles published for
securities law seminars nationwide.
TEACHING
EXPERIENCE:
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STANFORD
UNIVERSITY SCHOOL OF LAW, Palo Alto,
California
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October
1990
Guest
Lecturer of Adjunct Professor C. Xxxxxxx Xxxxx for course entitled “Financial
Frauds: Civil and Criminal Remedies.” Topic: Xxxxxxx
Xxxxxxx.
INSTITUTE
FOR LEGAL STUDIES, Arlington,
Virginia
Instructor
October
1988 to December 1988
ADMISSIONS:
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Missouri, Illinois,
Pennsylvania
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LICENSES
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Series
7, 24, 63
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PUBLICATIONS:
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Xxxxxxx,
Xxxxxxxx & Xxxxxx, “RICO Reform: Will the Litigious Lion Be Tamed at
Last?”
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Inside Litigation,
Vol. 2, No. 1, pg. 32 (November 1987)