Joan Ohlbaum Swirsky is of counsel in Stradley Ronon's Investment Management/Mutual Funds Practice Group. Ms. Swirsky has counseled clients for more than 25 years, including more than 15 years advising investment companies on regulatory compliance and general corporate matters under the Investment Company Act of 1940.
Ms. Swirsky represents clients on a diverse range of investment company matters, with a specialty in issues related to money market funds operated in accordance with Rule 2a-7 under the Investment Company Act of 1940. Ms. Swirsky’s projects relating to money market funds include:
• review securities for eligibility under Rule 2a-7 as money market fund investments
• advise issuers desiring to structure Rule 2a-7-eligible securities
• address troubled holdings in money market portfolios, including related communications with the SEC staff
• develop and review money market compliance checklists and procedures
• advise regarding responses to SEC examinations and inquiries relating to money market funds
• present training sessions to portfolio personnel, board members and others relating to money market fund compliance
• handle day-to-day portfolio compliance issues for money market funds
Additionally, Ms. Swirsky has counseled investment company clients regarding:
• governance and federal securities law issues
• reorganization and start-up of new portfolios
• exemptive applications under the Investment Company Act
• advertising materials, anti-money-laundering requirements, “supermarket” and other agreements
• the preparation of registration statements, compliance policies and procedures, reports to shareholders and board meeting materials
• SEC filings, proxy statements and staff examinations
Ms. Swirsky is the author of The Guide to Rule 2a-7: A Map Through the Maze for the Money Market Professional – a 113-page handbook that addresses the complex requirements of Rule 2a-7 and offers direction on how to evaluate and revise products being offered for investment by money funds. She is frequently quoted by national media including the New York Times, USA Today, Bloomberg and Marketwatch, etc., on money market fund issues. Ms. Swirsky regularly conducts seminars on matters related to money market funds for, among others, portfolio managers, fixed income analysts, compliance and administration personnel and legal staff. She has also drafted, or participated in preparation of, numerous comment letters to the SEC on its Rule 2a-7 proposals, and assisted industry participants to crystallize their views expressed in these letters.
Prior to joining Stradley Ronon, Ms. Swirsky was investment management counsel at another Philadelphia firm. |
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