Experience

• • A global asset manager in an SEC exam focused on the impact of asset write downs on the management fee base in the post-commitment period that ended without a referral to the Division of Enforcement.
  • A leading private equity firm in an SEC exam focusing on artificial intelligence that ended with a “no findings” letter.
  • A New York-based investment management firm focusing on residential whole loans and mortgage servicing rights in its first SEC exam, which ended with a “no findings” letter.
  • A prominent global hedge fund adviser in an SEC enforcement investigation regarding off-systems communications.
  • The head of Retail Capital Markets of a specialty finance company in an SEC investigation concerning sales of bonds to retail investors.
  • A multi-strategy global asset manager in an SEC exam of their credit platform.
  • A New York-based hedge fund regarding management and governance issues.
  • A broker-dealer in an SEC enforcement investigation regarding Reg. SHO issues.
  • A leading private equity firm in SEC and DOJ investigations concerning employees’ personal investments.
  • A broker-dealer in a FINRA enforcement investigation related to the January 2021 meme-stock trading events.
  • A global asset manager in developing an information barrier.
  • Off-system communications regulatory compliance counseling, policy reviews, employee training, and remediation for numerous global asset managers, financial services firms, and public companies.
  • Robinhood in its SEC and FINRA settlements relating to best execution practices and payment for order flow.
  • Robinhood in its June 2021 global FINRA settlement relating to platform outages, options, and supervision.
  • A large private equity adviser in an SEC settlement involving allegedly improper expense allocations by its real estate investment portfolio company.
  • A large global hedge fund adviser in an SEC settlement related to alleged Rule 105 violations.
  • A business development company adviser and private fund adviser in their SEC settlement relating to alleged violations of co-investment exemptive order conditions.
  • A clearing firm and its subsidiaries in an SEC settlement related to its risk management policies.
  • A hedge fund in securing a declination from the SEC in connection with an investigation of its trades in the securities of a target company.
  • Tiber Creek Corporation and two individuals in their settlements with the SEC for alleged unregistered broker-dealer activity.
  • SolarWinds, a software developer, in an SEC investigation related to the December 2020 SUNBURST cyber attack.
  • A global pharmaceutical company in its settlement with the SEC for alleged disclosure failures.
  • A credit rating agency in its settlement with the SEC for alleged internal controls failures.
  • A leading real estate funds adviser in an SEC investigation related to its engagement of a service provider that resulted in a declination by the government.
  • A prominent global private fund manager in SEC/DOJ block trades investigation.
  • A prominent global hedge fund adviser in an SEC enforcement settlement involving rule 21F-17 whistleblower protection issues.
  • A large global hedge fund adviser in a SEC investigation related to Regulation SHO.
  • A registered fund complex in a SEC investigation related to fund fees and the 15(c) process.
  • A prominent global hedge fund adviser in multiple SEC and FINRA examination and enforcement matters.
  • A prominent private equity adviser focused on technology investments in various SEC /DOJ investigations.
  • Oaktree in its settlement with the SEC relating to alleged violations of the pay-to-play provisions of the federal securities laws.
  • A leading fund-of-funds adviser in an SEC/DOJ investigation related to an underlying investment.
  • A Fortune 500 life insurance company and its subsidiaries in two SEC investigations.
  • A prominent fund administrator in SEC investigations involving odd lot valuation and expense allocation issues.
  • A large private equity firm in an SEC insider trading investigation involving personal trading activity.
  • A private equity adviser in an SEC investigation related to allegations of conflicts of interest and improper gift giving.
  • A chief financial officer of an international energy services company in an SEC investigation related to revenue recognition practices.
  • A hedge fund in an SEC investigation related to revenue recognition practices.
  • A large financial services institution in SEC investigations focused on its share class selection and revenue sharing arrangements that resulted in a declination by the government and of Thrift Savings Plan rollovers.
  • A large financial services institution in an SEC investigation of its sales practices and revenue sharing arrangements that resulted in a declination by the government.
  • A high-profile financial information content provider in an SEC investigation that resulted in a declination by the government.
  • A prominent hedge fund adviser in SEC investigations related to CDS and other trading.
  • An investment management firm in an SEC investigation related to fee disclosures and MNPI policies and procedures.
  • An investment advisory firm in an SEC enforcement settlement related to disclosures regarding the methodologies used to construct a proprietary index created to depict performance of a convertible bond investing strategy.
  • A fixed income hedge fund adviser in an SEC investigation related to alleged cross transactions that resulted in a declination by the government.
  • A CDO manager and its affiliates in an SEC examination.
  • A family office of the principal of a large private equity firm in negotiating a compliance governance framework between the family office and the firm.
  • A Fortune 100 financial services company in an internal investigation related to soft dollars.
  • Dozens of leading private equity fund and credit fund advisers in SEC examinations focused on fee and expense allocations, conflicts disclosures, secondary transactions, relationships with affiliates, and alleged pay-to-play rule violations.
  • Prominent private equity fund and hedge fund advisers in fee and expense allocation remediation projects.