Stradley Ronon maintains one of the premier investment management practices in the United States, representing investment company clients with more than 1,000 separate funds and assets under management approaching $2 trillion, including several of the largest investment company complexes in the country.
Our Investment Management/Mutual Funds Practice Group represents retail and institutional investment companies marketing shares through every distribution channel, as well as investment advisers, hedge fund sponsors, managers, administrators and underwriters/distributors. We also serve as independent legal counsel to investment company independent directors/trustees, and as special counsel to other law firms with regard to complex issues arising under the Investment Company Act of 1940.
The foundation of Stradley Ronon’s Investment Management/Mutual Funds practice is its recognized capability to advise and assist in all facets of an investment fund’s legal operation – from evaluating a client’s strategies on forming a mutual fund, to assisting with potential transactions. We advise clients daily on:
- managing and directing the annual update process, including scheduling, organizing and preparing documents
- drafting, reviewing and, in certain instances, filing registration materials for new mutual funds, including cutting-edge or novel products
- preparing and reviewing board memos and other materials, and attending board meetings
- preparing attendant documents for complex fund restructurings and reorganizations
- preparing exemptive applications and no-action letters, and shepherding them through regulatory channels
- participating extensively in the representation of our clients in SEC or other state enforcement actions
- addressing complex tax issues arising in the formation and operation of mutual funds
Stradley Ronon is also actively involved in helping clients respond to the changing investment management environment, including sweeping SEC initiatives. We have worked with fund clients, CCOs and boards to address crucial issues as they arise, including:
- implementing and testing compliance policies and procedures adopted under the new SEC rules
- counseling on novel disclosure issues, including the use of derivatives by funds and various corporate governance and transparency initiatives
- strategizing and counseling on new product development, including formation of alternative investment entities, such as hedge funds, multi-manager funds, funds of hedge funds and offshore funds
We address a full range of issues for our clients, including those related to:
- 1940 Act Registered Funds
- Exchange-Traded Funds
- Independent Directors/Trustees
- Investment Advisers
- Money Market Funds
- Corporate & Finance
- Hedge Funds
- Asset Manager M&A
- Securities Enforcement
- Closed-End Funds
- Alternatives Funds
- CFTC Regulation
Stradley Ronon has a long and rich history assisting clients with new and innovative investment products addressing industry trends in portfolio management.
Stradley Ronon name partner Andrew Young helps to establish the Wellington Fund, one of the first mutual funds in the United States. Today, the Wellington Fund is a member of the Vanguard family of funds and continues to be managed by Wellington Management Company.
Mr. Young forms the investment firm that ultimately becomes Delaware Management Company. He also forms that firm’s flagship fund, the Delaware Fund. Stradley Ronon continues to represent both DMC and the Delaware Fund today.
The Investment Company Act of 1940 is enacted into law. Mr. Young attends the Congressional hearings leading up to its enactment.
Stradley Ronon creates one of the first fund-of-funds structures in the industry. Our firm drafts and negotiates with the SEC the exemptive application that leads to the creation of The Vanguard Group, Inc., which remains one of the most unique and innovative structures in the industry.
Prior to the adoption of Rule 18f-3, Stradley Ronon drafts one of the very first multiple classes’ exemptive applications. We establish master/feeder structures, which involve the conversion of funds to such structures, as well as the establishment of such structures anew.
We structure and establish a very unique product for a major fund complex, which leads to the establishment of an institutional fund organization that could invest a portion of its assets in other affiliated funds for asset allocation purposes, and not as a traditional fund-of-funds. The fund organization is established as a 40 Act only registered vehicle.
Stradley Ronon drafts and establishes one of the first unregistered money-market sweep vehicles in the country.
We establish certain fund structures that are used for investment by wrap fee products, which are modeled after the one originally established for PIMCO, known as the “FISH” product.
Our attorneys secure a no-action letter from the SEC, giving a major mutual fund complex permission to participate in the Term Asset-Backed Securities Loan Facility (TALF). This letter has served as the principal guidance for the industry with respect to TALF.
On behalf of a client, we obtain the first manager-of-managers exemptive order that covers both affiliated and unaffiliated sub-advisers since the SEC stopped issuing such orders in the 1990s.
We continue to counsel clients on innovative registered funds with exposure to commodities, real estate and other complex derivatives. Our attorneys counsel on large fund reorganizations, evolving CFTC regulations, fund-of-funds structures involving unregistered pooled vehicles (domestic and offshore), closed-end funds and hybrid vehicles, such as interval funds.