Joan Ohlbaum Swirsky

Joan Swirsky


Joan Swirsky is a seasoned investment management attorney with a nationally respected focus on money market funds operating under Rule 2a-7 under the Investment Company Act of 1940. Joan authored the definitive guide on the subject area entitled “The Guide to Rule 2a-7 – A Map Through the Maze for the Money Market Professional.” The book is so well respected that even industry regulators have ordered copies. Joan, one of the foremost practitioners and thought leaders in legal issues concerning money market funds, is widely quoted in the national press. She is highly regarded for her ability to clarify complex provisions in jargon-free layman’s terms, whether providing detail for compliance personnel or a broad overview for a fund board.

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Representative Matters

Money market fund projects Joan has handled include:

  • reviewed securities for eligibility under Rule 2a-7 as money market fund investments
  • advised issuers on the structure of Rule 2a-7-eligible securities
  • addressed troubled holdings in money market portfolios, including related communications with the fund board, the public and the SEC staff (such as seeking no-action relief)
  • sought relief from or advice of regulators regarding interpretative questions under money market fund regulation
  • developed and reviewed money market compliance checklists and procedures
  • advised regarding responses to SEC examinations and inquiries relating to money market funds
  • advised regarding SEC enforcement proceedings involving money market funds
  • presented training sessions to portfolio personnel, board members and others relating to money market fund compliance
  • handled day-to-day portfolio compliance issues for money market fund

Projects relating to investment company work include:

  • drafted registration statements and other disclosure documents
  • responded to SEC staff examinations
  • addressed affiliated transaction issues under the Investment Company Act
  • advised on board reporting issues
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Bar Admissions
  • Pennsylvania
  • New Jersey
  • New York
  • J.D., Harvard Law School
  • A.B., cum laude, Cornell University

Speaking Engagements

  • Panelist, “Money Market Funds: 2014 Fundamental and Other Reforms and 2015 Reforms to Remove References to Ratings,” Securities and Exchange Commission
  • Moderator, “Money Fund Reforms: Outstanding Issues,” Crane Money Fund Symposium
  • Panelist, “More on MMF Reforms: Adoption Issues,” Crane Data’s Money Fund Symposium
  • Presenter, “Will You Be Ready? Implementing the New Money Market Fund Rules,” Investment Company Institute
  • Presenter, “Questions and Answers on Money Market Fund Final Reforms,” Practicing Law Institute
  • Presenter, “What You Need to Know About Money Market Fund Reform,” Philadelphia Bar Association Investment Companies Committee
  • Presenter, “Money Market Fund Reform: What the Board Needs to Know,” Mutual Fund Directors Forum
  • Presenter, “Money Market Funds: Status and Reform,” Securities Industry and Financial Markets Association (SIFMA) Operations Conference
  • Presenter, Money Market Funds Asset Management Forum, SIFMA
  • Presenter, “Money Fund Regulation: 2a-7 Basics and History,” Crane Data Money Fund University
  • Presenter, “Money Market Funds: The Shifting Regulatory Landscape,” SIFMA Operations Conference
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