Sandra M. Rocks’ practice focuses on commercial financing, including secured transaction and bankruptcy law.

Sandra joined the firm in 1980 and became counsel in 1990.

Selected Activities

  • Serves on the TriBar Committee on Legal Opinions and participated in the preparation of TriBar’s original and updated reports on security interest opinions under Article 9 of the Uniform Commercial Code (UCC)
  • Former Chair, Task Force on Cleared Swaps of the American Bar Association Business Law Section UCC Committee; former Co-chair, Investment Securities Sub-Committee of the UCC Committee (two nonconsecutive terms); and former Chair, International Commercial Law Subcommittee of the UCC Committee
  • ABA Liaison-Advisor to the Permanent Editorial Board of the Uniform Commercial Code, 2005 to 2008
  • Served on the Subcommittee on Investment Securities’ Task Force on Proposed Treasury Regulations Governing Book-Entry Securities, which studied and provided comments to the U.S. Department of the Treasury on regulations governing book-entry Treasury securities
  • Participated on behalf of EMTA (formerly the Emerging Markets Traders Association) in UNIDROIT projects to create Netting Principles (finalized May 2013) and the Convention on Substantive Rules for Intermediated Securities (finalized October 2009), also acting as a co-coordinator for the private financial sector for UNIDROIT's Study Group on this project, and in the development by The Hague Conference on Private International Law on the Law Applicable to Certain Rights in Respect of Securities Held with Intermediaries (finalized December 2002)
  • Member, Subcommittee on Legal Issues of the Group of 30 Global Monitoring Committee, 2005
  • Participated as an industry expert in connection with the United Nations Convention on the Assignment of Receivables in International Trade (finalized in 2004)
  • Member of the Securities and Exchange Commission's Market Transactions Advisory Committee, established to advise ways in which to reduce risk in the efficient clearance and settlement of market transactions; chaired the bankruptcy subcommittee of that group, which issued its final report in 1997
  • Member of the executive committee of the board of directors of Susquehanna University
  • Member of the executive committee of the board of directors of Hazon
  • Member of the American Law Institute and a member of the American College of Commercial Finance Lawyers


Third Circuit Holds ‘Triangular Setoff’ Unenforceable in Bankruptcy,” Cleary Gottlieb Alert Memo, March 25, 2021 (co-author with Lisa M. Schweitzer, Sean A. O'Neal, Luke A. Barefoot, Jane VanLare, Penelope L. Christophorou, Kara A. Hailey, and Brandon M. Hammer); republished by Law360

Federal Reserve Finalizes Expansion of Regulation EE’s “Financial Institution” Definition,” Cleary Gottlieb Alert Memo, March 8, 2021 (co-author with Colin D. Lloyd, Hugh C. Conroy, Jr., Penelope L. Christophorou, Brandon M. Hammer, Lauren E. Gilbert, and Graham Richard Bannon)

Summary of U.S. Financial Sector Initiatives Responding to COVID-19,” Cleary Gottlieb Alert Memo, April 10, 2020 (co-author with Derek M. Bush, Katherine Mooney Carroll, Hugh C. Conroy, Jr., Michael H. Krimminger, Colin D. Lloyd, Michael A. Mazzuchi, Jack Murphy, Penelope L. Christophorou, Carl F. Emigholz, Allison H. Breault, Patrick Fuller, and Lauren Gilbert)

AG MIT CMO, LLC v. RBC (Barbados) Trading Corp.: Initial Post-COVID-19 Litigation Challenges to Closeouts of Repurchase Agreements,” Cleary Gottlieb Alert Memo, March 31, 2020 (co-author with Carmine D. Boccuzzi Jr., Rishi N. Zutshi, Penelope L. Christophorou, Lisa M. Schweitzer, Jane VanLare, Brandon M. Hammer, Sean A. O'Neal, Douglas A. Gretz, Colin D. Lloyd, Derek M. Bush)

Custody Transfer of Digital Assets: Key U.S. Legal Considerations,” Global Legal Insights to: Blockchain & Cryptocurrency Regulation 2020, October 28, 2019 (co-author with Michael H. Krimminger and Colin D. Lloyd)

Federal Reserve Board Proposes to Expand Netting Protections of FDICIA to Additional Institutions,” Cleary Gottlieb Alert Memo, May 23, 2019 (co-author with Michael H. Krimminger, Colin D. Lloyd, Penelope L. Christophorou, Knox McIlwain, Brandon M. Hammer, Lauren Gilbert and Ellen Campbell).

Treasury Report Embraces Machine Learning and Artificial Intelligence in Financial Services,” Cleary FinTech Update blog, August 29, 2018; republished by The Journal of Robotics, Artificial Intelligence & Law, January–February 2019 (co-author with Pamela L. Marcogliese, Colin D. Lloyd, and Lauren Gilbert).

Supreme Court Holds Section 546(e) Safe Harbor Does Not Apply to All Transfers Made Through Financial Institutions,” March 1, 2018 (co-author with Seth Grosshandler, Mike Krimminger, Lisa Schweitzer, Sean O’Neal, Luke Barefoot, Penelope Christophorou, Humayun Khalid, Knox McIlwain, Thomas Kessler, and Brandon Hammer), republished on March 29, 2018 by ABA Business Law Today.

“The ABCs of the UCC, Article 8: Investment Securities,” The American Bar Association Second Edition, January 2015 (co-author with Carl Bjerre).

“Survey of International Commercial Law Developments,” The Business Lawyer’s August editions, 2001 to 2004 (co-author).