Norm Champ Partner of Kirkland & Ellis Discusses Hedgefund Investments and Going Public
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I interviewed Norm Champ on April 21st, 2017. We discussed how he came from a hedge fund to the US Securities and Exchange Commission (SEC) and eventually being the Director of the Division of Investment Management and then now a law partner in the New York office of Kirkland & Ellis. Norm shared stories from his new book Going Public: My Adventures Inside the SEC and How to Prevent the Next Devastating Crisis. He shared about what surprised him inside the Federal Government and some of the challenges he was faced with. He shared how they would have discovered Bernie Madoff through a couple changes and how they hope to prevent a situation like that again. He shared some of his interactions with the Hill and people he met. He shared his interactions with FSOC and their influence with SEC’s role in regulating US mutual funds, investment advisors and other investment firms. He shared the people in his life who inspired him to be in public service and give back to the country. Finally, Norm shared what books should be written that are not yet.
Here’s some highlights of my interview with Norm Champ:
“They never sent that letter. If that letter were sent, Madoff would have been unmasked years before he was unmasked and investors could have saved billions…”
“[The current administration and the SEC] are very focused on getting companies to go public in the United States and make sure that we continue to be one of the centers for people to come here and go public.”
“[Book recommendation] I’d really like to see a much better examination of the government policies that led to the 2008 crisis.”
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Links referred to in this episode
Norm Champ Law Firm Bio
Norm Champ Speaking Writing Website
(Book) Going Public: My Adventures Inside the SEC and How to Prevent the Next Devastating Crisis – released March 2017
Bernie Madoff
Allen Standford
SEC Division of National Exam Program
SEC Division of Investment Management
Financial Stability Oversight Council
Scott Alvarez, General Counsel of the Federal Reserve
Mary Jo Wright, SEC Chair
Jay Clayton, SEC Chair nominee
Judge Charles Haight
Patrick O’Shaughnessy & Invest Like the Best Podcast
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Audio Transcription
To Download the Transcript of this Audio, click here. (Look in the top right corner and click on the three dots to download.)
Hello listeners, this is Chris Batz, your host of the Law Firm Leadership podcast. As a reminder, the transcript of this audio will be available on my site to read or download. If you appreciate this episode or others and haven’t already, please leave a review on iTunes. This makes the podcast more visible. Finally, I provided in the show notes of your device links to the subjects mentioned in this episode and a link to the transcribed audio.
As many of you know, we interview corporate defense law firm leaders, partners, general counsels and legal consultants. You are listening to Episode Ten of the Law Firm Leadership podcast.
Chris: Welcome to the Law Firm Leadership podcast, I’m your host, Chris Batz with The Lion Group.
Today I have the pleasure of speaking with Norm Champ of the prestigious law firm Kirkland & Ellis. Norm joined the New York office of Kirkland & Ellis February 2016 as a partner in the investment funds group. Just prior, Norm was the director of the division of investment management at the SEC, playing a crucial role in the three trillion dollar money market fund industry and led important structural changes within the SEC.
Norm, you started at the SEC in 2010 as the deputy director of the exam program. You were also the executive vice president and general counsel of Chilton Investment Fund, which is a Connecticut hedge fund, and started your career at Davis Polk. You received you’re A.B., summa cum laude, in history from Princeton University and a J.D., cum laude, from Harvard Law. You also were a Fulbright Scholar at King’s College London, were you received your M.A. in War studies. Welcome, Norm to the Law Firm Leadership podcast. It’s a pleasure to have you on the show.
Norm: Great. It’s a pleasure to be here. I look forward with speaking to you today and speaking to all of your listeners.
Chris: Norm, you are now a published author and I wanted the audience to know that you released a book this past March called, Going Public: My Adventures Inside the SEC and How to Prevent the Next Devastating Crisis. Let’s kick off this interview with what surprised you once you were inside the SEC and working for the government.
Going from a Hedge Fund to the Federal Government and Surprises
Norm: Sure, absolutely. And I think really the book is about that journey and its title of chapter one is Fish out of Water, so I mean, that kind of sets the tone, right? You’re coming from a private fund, coming from private investment management industry and moving into the government. And it is a big shift. It’s a very different world inside the government. It’s also a very personal decision to go into public service. And obviously right now we have a number of people who are leaving, you know, New York to go down to Washington and do public service. It’s a big personal step. I mean, just among other things, every single asset you own is listed on a schedule and that schedule is available to the public, so it’s pretty invasive. And it’s a big change in kind of everything you’re doing.
The biggest surprises are maybe some expected and some unexpected. I would put in the category of the single biggest surprise the lack of comprehensive policies and procedures about how the exam program conducted examinations and went about its business conducting examinations of investment advisors, broker dealers, credit rating agencies, all the different entities that were being examined. And so along about my second week, some of the exam supervisors asked me about a certain exam and said “Well, what do you want us to do in this situation? How should we do this?” And I sort of looked at them and said, “Well, wait a second guys, I’m happy to be here, but I did just walk in off the street, right? And don’t we have some policies around this? Do we have some frameworks? What do we look to?”
And it developed that while there were certain discreet pieces about how you did sort of parts of exams and, you know, technical issues, there was no overarching set of policies and procedures about how the examination program did its work. And similarly, when I got to the division of investment management, also no set of policies and procedures. Now, that doesn’t sound maybe that, you know, glamorous, well policies and procedures, but these are critical items when you’re thinking about doing the examinations of investment advisors.
Chris: Absolutely.
Madoff Would Have Been Unmasked Years Before and Investors Saved Billions
Norm: And so if you think about something like Madoff, where years before Madoff was caught, the examiners were on site looking at his operation. And they drafted a letter to the National Options Exchange saying, please send us Mr. Madoffs trading records. That letter was never sent. The examiners were concerned about what information they would get back. They were concerned about getting the exam closed. They never sent that letter. If that letter were sent, Madoff would have been unmasked years before he was unmasked and investors could have saved billions because, of course, the the Options Exchange would have come back and said the guy is doing no trading at all and that would have been the end of that. So, not surprisingly, the manual for the exam program says, look when you go out to a business, you’ve got to make sure you have some third party assurance that this thing is real, right? You can’t just take the word of the people on site. So that’s just a simple thing that wasn’t there.
What that meant was that examiners didn’t really have a great chance for success. So I’m a big believer in there aren’t too many bad people, but there’s bad systems and bad management. And I think the examiners were not given the right tools and the right framework to be successful in finding something like Madoff. So certainly the lack of those written policies and procedures both in exam and in the Division of Investment Management were the biggest surprises. And we were able to get in place comprehensive manuals for both groups and those manuals are still being used today. And that’s something that I’m very proud of and also something that I believe will last because once they’re in place people will look at them, so I think that was a huge step forward for protecting investors.
No Carrots to Reward Good Behavior and Impossible to Fire Poor Performance
Some of the other surprises I think are more expected probably. You, as managers in the SEC we faced a number of management challenges, so if there is no pay for performance system at the SEC, so what I call, there are no carrots, right? If people work harder, they don’t get rewarded. And we did numerous employee surveys and that was always the least popular feature that people would write in about was that they felt like there was no reward for working harder, so why do it. So the lack of carrots, the generally just salaries go up automatically under the union collective bargaining agreement, and there is no way of distinguishing among folks except for some very small bonuses for some very senior people. So you don’t have that reward to the upside. Similarly, there is no downside, so once employees have been through a probationary period at the SEC, it’s almost impossible for them to be fired.
Chris: That’s amazing.
Norm: So between civil service rules and union rules, very difficult for anyone to ever be fired on the downside. So, as managers that’s difficult when you sort of take away the incentives and you take away the downside. So we what we tried to do is think about what motivated people, what were people really interested in. You know, some people really want recognition, so we would try to get them recognized in press releases and so forth about matters that we had brought, other people deathly afraid of having their name in a public document, but they would like an award within the division or they’d like some kind of recognition internally, right? So we tried to find ways to motivate folks in what’s a pretty difficult management environment. Now, a strategic decision that I made early on was-
Chris: Forgive me Norm, I mean, you couldn’t fire people?
Norm: No, because, you probably know that civil service protections came into place actually a little bit over 100 years ago and they were a very, you know, it’s goals in civil service that we could all agree with, right? You don’t want the new president to come in and be able to fire everyone and then hire all his own people, right?
Chris: Sure.
Norm: That’s why civil service reform – that’s why civil service eventually was put in place in the United States. Again, we could all agree with that. It’s been added to over the years so that that simple concept has turned into a very complicated system with appeal boards and processes all over the place, so it’s that to actually move somebody out is pretty much impossible. And that is, it’s a big challenge because it makes it difficult to manage the group. And so-
Chris: You can’t get consistency or anything across that and-
Norm: Yeah, no, it’s tough. And as I was saying, you know, one of the strategic decisions I made was to really try to work with the public employee union. So public employee union, you know, has a number of roles by contract and by law at the SEC. And there were managers who felt very uncomfortable with the public employee union and some of the demands that the public employee union makes. You know, so initially the collective bargaining agreement years ago allowed for one day of work at home, and the next one allowed for three days of work at home, and then the latest collective bargaining agreement allows five days of work at home for certain groups.
Chris: Wow.
Norm: And so there were people who, you know, were very concerned about that. And, you know, certainly I had issues with some of that stuff as well, but I basically took kind of a bigger picture approach and said look, the union’s been here long before we got here and they’re going to be here long after we got here, and so if we want to get some change made, we’re going to have to work with them. And so I pretty much spoke to the union leadership every Tuesday morning for five years and they helped me make substantial change in the exam program, substantial change in the investment management division, and we accomplished more change I think than anyone thought was possible and that was due to that collaboration with them.
And remember, they had some motivations of their own. Examiners had been featured in the New York Post. There was a picture of an examiner who had worked on Madoff. And there was like a photo of her with a caption saying, you know, this person missed Madoff and so forth. So the union was in a frame as well to try to change some things and so we worked together really well. In the exam program, we got the manual in place as we discussed. Also brought in a lot more experts to help with the exams and help people, help the examiners understand the industry better. As you note, I was certainly the first person who’d even been a partner in a hedge fund who was hired at the SEC. I think they may have, I think there were some people who feared I would show up with horns and a tail. But, you know, we hired many more experts after that to help the examiners. And we also got in place some significant changes to put more supervisors in the field so that examiners weren’t necessarily on their own when they were out in the field. And then critically we got in place automated examination reports across the whole United States, so that was huge because exam reports had literally been done in paper form and placed in local files around the country.
Chris: Wow.
Norm: And that was very difficult for coordinating efforts or trying to compare notes or track, you know, track issues around the country. So we got an automated exam report function so that all the exam reports were electronic and can be compared across the United States.
That was huge particularly in the context of something like Allen Stanford, right? So Allen Stanford was running a massive Ponzi scheme down in Texas. Examiners had looked at him, I think it’s more than a decade before he was arrested, and they wrote a report saying we think this guy is running a Ponzi scheme or it’s a possible Ponzi scheme, something like that. They tried to get enforcement folks interested in bringing an investigation of Stanford, but they couldn’t. You know, here were issues like he’s in Antigua. He supposedly, you know, had a bank in Antigua that was paying these high interest rates and there were concerns about how to investigate that. The examiners tried for a bit and then when it didn’t work out, they put the report back in a file and they went on, right? So you won’t be surprised to learn that the manual says hey, if you believe someone is committing fraud, you have to escalate that up the chain of command all the way to the Director of Exam and the Director of Enforcement if it comes to it.
So we were able to get these things in place and able to make some changes that I think were really beneficial to help the examiners do their job and make sure that they would be more successful in protecting investors.
Chris: What else? I know that you had interacted with the Hill to actually get something done and assess what the needs were. What were your interactions with post-financial crisis, ongoing financial crisis as you’re trying to protect. I mean you mentioned you had interacted with senators, the Fed. Did you find any characters that were either fun or interesting to deal with?
The SEC, Bringing Change Through Congress and Characters on the Hill
Norm: Absolutely. I mean, I would put in the other surprise category and this one would be I would put in the more unexpected category. You know, in my whole career as a lawyer, you’re just sort of thinking of the SEC as this very powerful organization that could make trouble for your client, you know, and do enforcement actions. And so I think one of the surprises when I got there is kind of just like any other organization, the SEC is buffeted by all sorts of demands and all sorts of stakeholders and all sorts of people who have, you know, an interest in what happens, right? So you get there, and this is particularly true, this is true in exam, but also true in investment management, you know, director of investment management sounds great, but it’s not like you get to wave a wand and decide what policies are pursued, right? You’ve got, as you mentioned, you’ve got Congress, you’ve got the press, you have the executive branch, you have the commissioners and the chair. I mean there’s a lot of constituencies that you are responsive to and that you interact with.
So as far as the Hill, I think that, you know, we veer off and would go over to the Hill, speak to them about various policy issues. I’d break that in two halves. On the exam side, my time in exam, we were obviously having to explain to the Hill how Madoff and Stanford happened, what were we doing about trying to remedy the issues at the SEC that had led to Madoff and Stanford, and we had to explain, you know, how we were moving forward from those disasters so that, you know, that was a big part of the interaction with the Hill.
And then when you move into investment management, the relationship with the Hill is a little different. That tends to then be dialogues about policy, and what are you doing about this, and what are you doing about that policy, what are you doing about money market funds, as you mentioned in the intro, what are doing about other issues in the investment management industry, how come it takes so long to process certain applications through the SEC, why is that happening. So you’re responding to questions constantly from the Hill, and going over and speaking with them, and briefing staff, and, you know, that’s just sort of constant part of what’s going on.
Fending off the Financial Stability Oversight Council (FSOC)
We also had a lot of interaction with the Federal Reserve. So Dodd-Frank created a financial stability oversight counsel, FSOC in the abbreviation and that group was the ten federal financial services regulators that Dodd-Frank put on that council that included the SEC and the CFTC, but also the Federal Reserve, Office of Comptroller of the Currency, FDIC, Treasury, kind of all the players in the financial sphere. And there, you know, the issues really revolved around the fact that the SEC struggled from 2012 to 2014 to come up with the reforms for the money market mutual fund industry.
Just going back two seconds, the, during the crisis a massive money market fund, Primary Reserve, had run into trouble because it held Lehman Brothers short-term paper and when Lehman Brothers went under, the fund threatened to break the buck. Ultimately that created a run on all money market mutual funds and the Fed and Treasury had to step in and guarantee those funds. That, the SEC passed some quick reforms in 2010 after the crisis, but then in 2012 was unable to agree on further money market fund reforms right when I got into the job. It took us two years to forge a compromise and get a final rule passed about the money market mutual funds. We got that done in the summer of 2015.
But in those two years, ’12 to ’14 while we were struggling with our own internal issues, the Financial Stability Oversight Council was sort of looking over and saying “Well, do these guys have a handle on asset management? Are they, you know, appropriately regulating it?” So not only were we forging a compromise internally about money market mutual funds, but we also had to fend off the FSOCs desire to get into regulating asset management, so we sort of had two different funds going on at once. In addition, a subset of the Financial Stability Oversight Council, five regulators, were in charge of drafting the Volcker Rule to separate risk-taking activities at banks and so I worked with the other agencies on that.
The Most Powerful Man in Washington You’ve Never Heard Of
Probably the best character from all those interactions has to be Scott Alvarez, the general counsel of the Federal Reserve. I tried to paint a portrait of him in the book. Wonderful guy, you know, career guy at the Fed, wielded tremendous influence at the Federal Reserve because he had been there so long. He’s a general counsel. He’s drafting the Federal Open Market Committee minutes that are so watched by Wall Street and the rest of the world about interest raises, all those kinds of things. So he’s a busy guy and had a lot on his place including Volcker and including the FSOC type things. And we interacted a lot, tremendous professional and a guy who just recently announced his retirement. And so he certainly was one of the colorful characters. I think the Journal or Times or somebody ran a profile of him, you know, The Most powerful Man in Washington You’ve Never Heard Of. So I got to spend a lot of time with him.
Chris: That’s excellent. I couldn’t help but want to pull out a quote from an article I read about your book and your experience. You describe the oversight council as the “Frankenstein-ish super regulator staging a hostile takeover, the SEC’s role in regulating American’s mutual funds, investment advisors and other investment management firms.” Do you think that would have happened if there wasn’t someone with your leadership or someone else in that role? Do you think we would see something different?
Norm: I guess, you know, I only, you know, you’re there, you’re playing the role you’re playing and there’s many, many people helping you, but I guess I would say that if you had a different person in charge of investment management at the SEC and a different chair, you know, Mary Jo White, I believe in the book I compare her to Winston Churchill in this battle. She was tremendously supportive of making sure that we were able to explain to the Financial Stability Oversight Council why the SEC should be in charge of asset management and why people on the Financial Stability Oversight Council who are bank regulators mostly should not be in charge of asset management in the United States.
Our markets are very deep and they’re the envy of the world. Those markets depend on an asset management industry that’s willing to put money into the securities on those markets. And it was critically important for US, you know, the future of the US, of the US as a financial center that we preserve the SEC’s role and we preserve the asset management industry. It’s not a bank account, right. You don’t put money in a mutual fund to have a bank account. You’re putting it in there to take risk and to get a return. And that’s the key of our markets. And so I do think we were able to dissuade the FSOC from getting into this area.
Part of that too was we had created in the Division of Investment Management a Risk and Examination Office staffed with our own quants, who were able to analyze a lot of the data that we had about asset management and who were able to go toe to toe with the Feds’ economists and that meant a lot to explain our regulation of the industry and make sure that the Fed and FSOC didn’t come in and take us over. So it was quite an episode. It’s obviously covered in the book and it certainly kept us on our toes. But I think it worked out in the end because we got money market mutual fund reform and we kept the Financial Stability Oversight Council away from regulating asset management.
Chris: Yeah, grateful for your leadership in that, Norm. I know you had suggested already some solutions, you were part of those solutions to allow FSOC not, in essence, doing a hostile takeover. I mean with a new presidency and lots of eyes on Wall Street, where do you see the future? I mean, I’m curious now that you’re out of government, at a law firm working with clients in the investment fund business, I mean, how are you guys positioning yourself and if you had a magic ball, what are you seeing for policy for the next four years?
Policy Priorities and Helping Companies Go Public
Norm: So I think the president and his nominee for chair of the SEC Jay Clayton have been fairly clear about some of their priorities. I think that they are looking to ease up on, you know, some of the constant flood of regulations coming out of Washington. You see the Executive Order, you know, you have to get rid of two rules to add a new one. And frankly we talked about that a lot when we were at the SEC, you know, it’s always more, right? You’re always adding. No one ever goes back and looks at the cumulative effect of all that or figures out a way to undo some of it. So I support them in that mission.
I think specifically if I had to use my crystal ball, as you said, I would say that they are very focused on getting companies to go public in the United States and make sure that we continue to be one of the centers for people to come here and go public. Overall, the number of IPOs in the United States, the average number of IPOs since 2000, is significantly lower than the average number of IPOs in the United States, you know, average annual number, pre-2000. So we’re in kind of a long term decline on companies going public here and I think that the president and the chair nominee have made it clear that they would like to reverse that trend.
You’ve seen that already. They used the Congressional Review Act to rescind the oil and gas extractive payment rule that the SEC had passed, making public companies disclose their oil and gas payments to other, you know, to people getting oil and gas from. That rule, I mean and I express no view on carbon or any of that other stuff, but that rule was not about shareholder value, that rule was about the politics of carbon, right? And I think that by rescinding that, you are taking that off public companies. You are taking that burden off of them. I think similarly the conflict minerals rule, which has been not a good result from that rule, I think they’ll try to, you know, get rid of that. Pay ratio, some of these other things that are making it less attractive to go public here, I think they will try to roll back some of those things so that they can encourage people to go public here.
As I mentioned earlier, our markets are one of the shining strengths of the US economy and I think that we’ve got to make sure that we preserve those markets. One hallmark of that is when we were at the SEC non-US governments would fly us all around the world at their expense to go and help them think about how to have free markets, how to have markets that are regulated and are places to raise capital. That just shows you the esteem that our markets are held in around the world and we’ve got to make sure we keep that leadership position for our markets.
Chris: Absolutely. And it’s interesting you describe this, obviously it’s aspect of your book, Going Public, from my observation I have noticed, especially because of the white collar criminal laws that have come out, just all the public companies moving away from our security exchanges and going to London or other parts of the world, do you think that’s going to be scaled back so they’re not scared to enlist on the New York Stock Exchange or other stocks or is it more about the scrutiny that you’re describing and kind of the disincentives?
Norm: I think there have been many reasons that IPOs are down in the US. A lot of it’s regulatory stuff, is a factor. Remember also the JOBS Act allowed private company in the United States to have up to 2,000 holders without going public. That number used to be 500 so that’s been a factor. There are multiple factors. And we have more competition from Hong Kong, London, China. So there’s, there are many factors, but I believe they will focus on some of these regulatory items to try to make the climate here a little more friendly for companies because we just can’t afford to lose our market position.
Chris: Yeah, yeah. Critical. I just wanted to ask because I know you’ve gone back in the law firm and would you ever consider another opportunity to go back into government or the SEC?
Norm: Sure. I would, you know, as I say in the book, look despite some of the challenges that I’ve described today and that I describe in the book, it remains the most rewarding professional experience of my life, you know, the opportunity to make policy in our area, in investment management at the top level of the federal government, I mean, there’s nothing like it. So I would certainly consider going back some day. I’m only a little over two years out, so I would like a little bit more of a break before that. I need a little more time off, but yeah, somebody certainly. I enjoyed it tremendously and there’s nothing like the people you serve with and the tremendous chance to impact policy.
Chris: Excellent. Well, I wanted to ask another question and so you’ve rolled out this book. It sounds like a very exciting, intricate story that people can follow up on the details of what you encountered in the SEC. I want to give credit to the question I’m about to ask from Patrick O’Shaughnessy’s podcast, Invest like the Best. He has his own hedge fund and he advises others and does a lot of interviewing on his unique individuals. And he, I listened to one of his podcast episodes, and he had this with two other gentleman, this exciting kind of conversation of what books are not being written, kind of inverting the book recommendation question. So the question is, you know, Norm, instead of you recommending other books, you know, what books should be written that haven’t been written yet? And I would love to get your feedback on that.
What Books Should be Written
Norm: I would say two. One is I think we need some better books about the 2008 crisis. You know, we had a spate of books right away. We’ve had a few since. I’d really like to see a much better examination of the government policies that led to the 2008 crisis. They tell us a lot about, one of the things I recommend in the book is that we spend more time making evidence-based policy decisions as opposed to policy decisions based on what sounds good.
So leading up to 2008, the United States government relentlessly pushed people into housing, right? They wanted people to buy houses. They wanted everyone to own a house. And that was done through low interest rates, guaranteed mortgages and then requirements that underserved populations get more mortgages and get houses. And all that sounds great, right? It sounds good. Oh, we want people to own houses. However, I think if we spoke to people who were foreclosed on in 2009 and 2010, they would not tell us a very inspiring message about home ownership.
And yet, so in the immediate aftermath of the crisis, the federal government raised the minimum down payment on a mortgage to 20 percent of the home’s value. And that was right after the crisis and I think that was a good policy move. And yet, only six years after the end of the crisis, so in 2014, the Obama administration dropped that minimum down payment for a guaranteed mortgage back down to three percent of the homes’ value, along with some, you know, supposedly stricter standards. But I just couldn’t believe that they would lower the down payment like that having just come off the crisis.
Chris: That’s amazing.
Norm: And I would submit that, I submit that as an example of making policy based on what sounds good as opposed to the reality. And so I’d love to see a book really talking about the reality of the government policies that led into the ‘08 crisis and how we could maybe do better as we make policy.
Norm’s Next Book on Personal Finance
The second one I would love to see is the one I’m going to write as my next one, which is going to be, which is going to be about personal financial planning and about, you know, how people, because the best remedy for the next crises is for individuals to have better balance sheets and better savings and better ability to withstand a crisis. And I’ve got a lot of ideas about how people can accomplish that and so I’ve already got an outline going of what might be the next book about how to insulate yourself from the next crisis by doing better with your own finances.
I’m sure everyone has seen the headlines, you know, people don’t have 2,000 dollars saved. They don’t have 400 dollars for a car repair, all these things. That’s at the same time that people literally spend billions on the lottery every year. Government advertises the lottery like crazy and that is a regressive tax on the poorest elements of the United States population. So I’d like to see a book really giving people a practical road map to financial success.
Chris: Yeah love it. And whenever you get that released, we’d love to do another interview and pull you in and have you share that passion you have.
Norm: Great, that would be fun.
Chris: So another question, you have some just tremendous, tremendous life experience and I’m a believer that people don’t get those opportunities simply by chance. It’s usually hard work. Some people have been inspired to go to that route. And so I just wanted to ask you, has there been anyone that’s really inspired you to get to the levels that you’ve been in life?
Norm’s Inspiration for Public Service
Norm: So I’d have to cite an early experience of public service that I discuss in the book, which is one year out of law school I went to clerk in the United States District Court for the Southern District of New York and specifically for Judge Charles Haight. And working for Judge Haight, you know my second and third years out of law school, being in court all the time with basically, you know, securities law type cases and then criminal cases, watching Judge Haight and his commitment to public service and, you know, the rewards of public service that he spoke so eloquently about, that was a major factor in kind of a lot of the things I’ve done since then. I didn’t appreciate everything he said at that time, I was a young whippersnapper, but I absorbed it over time and I think that, you know, his example of service really sunk in. And I, as I got farther along in my career, I was always in the back of my mind thinking where will the opportunity come to return to public service. And, you know, he definitely inspired me to that path.
I think then when the crisis came in ’08 and you know, in ’09 when things had calmed down a little bit, I really thought, hm, I bet you Congress does something. We didn’t know it was going to be called Dodd-Frank then, but I knew Congress would do something, had a feeling there might be some problems with it because there usually are. And I got to thinking that maybe my expertise would be helpful, you know, inside the government to help with that. So I started at the SEC six months before Dodd-Frank passed and it proved to be good timing and got to see a lot at the Commission. So I think the judge’s example really inspired me. Then once I got to the SEC, I worked for tremendous leaders, you know, Mary Schapiro, Elisse Walter, and Mary Jo White were the three chairs that I reported to and they were tremendous examples of leadership, so I was fortunate to work for all three of them.
Chris: That’s excellent. My hope is, and I’m sure it’s yours as you write and learn from and inspired from Judge Charles is, that listeners, attorneys, whether they’re in house, in government still or in private practice, that if they’ve been given the opportunity to serve, yeah, that your story will be one to inspire and to do their part in essence.
Norm: Well, thank you. I hope people enjoy the book and I really appreciate you having me on.
Chris: Absolutely. So stealing this question from Kai Ryssdal of Marketplace, Norm, in five words or less, what is your job?
Norm: Help funds comply with law.
Chris: That’s five. That’s excellent. Norm, it’s been a pleasure and honor to have you on the show. Thank you for your time.
Norm: Thanks so much for having me, really enjoyed the conversation.
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