DAVID SPECIALIZES IN PROVIDING REGULATORY COMPLIANCE COUNSELING TO REGISTERED INVESTMENT ADVISERS, INCLUDING PRIVATE FUND MANAGERS.
David has advised registered investment advisers on more than 200 SEC examinations. He leverages the information gained from these representations to advise private fund managers on their compliance programs and best practices, and to navigate SEC examinations. David also conducts mock audits designed to prepare investment advisers for SEC examinations.
David counsels investment advisers, including exempt reporting advisers, on the design and implementation of compliance policies and procedures, including the code of ethics, personal trading, marketing, insider trading, expert networks, best execution, investment allocation, valuation, expense allocation, conflicts of interest, business continuity, cybersecurity, and recordkeeping.
David regularly advises investment managers on compliance with new rules and regulatory requirements. He also advises U.S. and international investment advisers on SEC and state registration requirements and available exemptions.
David’s advice draws from a wealth of in-house experience, having served as chief compliance officer and senior counsel to SEC-registered investment management firms.
In addition, David has deep experience in the formation and representation of private funds, advising on offering documentation, investment management agreements, separate account agreements, solicitation agreements, seed capital arrangements, side letters, employment matters, non-compete and non-solicit agreements, non-disclosure agreements, brokerage agreements, and service provider agreements.
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