Joan Ohlbaum Swirsky has counseled clients for more than 30 years, including more than 20 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:
- reviewing securities for eligibility under Rule 2a-7 as money market fund investments
- advising issuers desiring to structure Rule 2a-7-eligible securities
- addressing troubled holdings in money market portfolios, including related communications with the SEC staff
- developing and reviewing money market compliance checklists and procedures
- advising regarding responses to SEC examinations and inquiries relating to money market funds
- presenting training sessions to portfolio personnel, board members and others relating to money market fund compliance
- handling 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
- 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, Second Edition – a 200-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 Wall Street Journal, The New York Times, USA Today, Bloomberg and Marketwatch, among others, 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 the 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.