Sarah Chen, JD
Eight years inside. Now writing it out.
Sarah spent eight years in the SEC's Division of Enforcement, where she led marketing-rule cases against registered investment advisors of every size — from solo practitioners to multi-billion-dollar firms. She worked the cases that shaped today's enforcement playbook, and she wrote the deficiency letters that wealth management firms now study line by line.
In 2024, she left the Division for the practitioner side, joining Holbrook Sterling LLP as a Partner in their RIA practice. There she advises wealth management firms on examination preparation, runs annual CCO training programs, and serves as outsourced compliance counsel to a roster of mid-market RIAs.
Sarah joined Healthy Volatility as the founding editor of The Compliance Desk because — in her words — "the gap between what examiners actually look for and what firms think they're being examined on is wider than anyone admits, and most of the existing thought leadership on this topic was written by people who've never sat across the table from a CCO during an exam."
She publishes long-form essays for the Desk twice monthly, authors the weekly Compliance Brief, and hosts roundtables on examination defence, AI governance, and the Marketing Rule.
What Sarah actually knows.
— Education & Bar
- JD, Columbia Law School (2014)
- BA, Yale University · Economics & Political Science
- Admitted to D.C., New York, Massachusetts Bar
- Federal Court · Southern District of NY
— Professional Recognition
- 2024 ABA Compliance Author of the Year
- 2023 Best Lawyers · Securities Regulation
- 2022 SEC Enforcement Director's Commendation
- Frequent contributor to Securities Regulation & Law Report
— Areas of Deep Expertise
- Marketing Rule enforcement & defence
- AI governance & supervision frameworks
- Off-channel communications policy
- Examination preparation & defence
- Custody Rule compliance
— Speaking History
- 50+ industry conference presentations
- 12 CLE programs as lead instructor
- Frequent panelist at SIFMA, NSCP, IAA
- Trainer for 4 of the top 10 RIA networks
"Sarah is the most credible voice on this side of SEC enforcement I've worked with. She doesn't speculate — she explains. Every CCO under my team has been required to attend her training."
On the roundtable stage.
Sarah's long reads.
The SEC's Quiet Pivot from Fiduciary Duty to AI Diligence
What RIAs Can and Cannot Say in Their Marketing in 2026
Off-Channel Communications: Why the 23-Firm Probe Is Just the Start
Reading the 2026 SEC Examination Priorities — Line by Line
Externally cited.
"Why Sarah Chen Says the AI Examination Playbook Has Already Shifted"
Cited in: "AI Governance for RIAs — A Practitioner Framework"
"Former SEC Attorney on the Five Marketing Rule Mistakes Still Costing Firms"
Quoted in: "The Q1 Deficiency Letter Patterns Most CCOs Are Missing"
What Sarah speaks about.
The 2026 SEC Examination Playbook — From the Inside
What examiners actually open with, what they're really looking for in Year 2 of the AI sweep, and which deficiency-letter patterns are accelerating.
AI Governance for RIAs: The Four-Layer Framework
The de-facto governance framework emerging from recent deficiency letters — Inventory, Risk Assessment, Supervision, Incident Response.
Marketing Rule Defence: The Documentation That Actually Works
Pre-publication review workflows, the documentation patterns that hold up under examination, and the deficiency-letter language to learn cold.
Off-Channel Communications: Beyond Email Capture
Why "we capture email" is not a defensible answer in 2026, and what a complete electronic communications supervision program now looks like.
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