A leader in the asset management field with more than 20 years of experience, Susan counsels clients with respect to U.S. Securities and Exchange Commission (SEC) and U.S. Commodity Futures Trading Commission (CFTC) registration. Susan regularly provides advice regarding required disclosures, compliance programs, structuring of new products and operations, complex regulatory matters, relief such as no-action letters and exemptive orders, SEC and CFTC/National Futures Association examinations, and regulatory advice in connection with acquisitions and similar transactions. Clients include registered investment advisers, exempt reporting advisers, private funds, registered funds, broker-dealers, funding portals, commodity trading advisors, commodity pool operators and other regulated financial participants, as well as entities exempt from regulation. In the area of exemptions, Susan is a well-known expert in investment company status determinations under the U.S. Investment Company Act of 1940 (40 Act). In this area, she regularly works with clients across diverse industries, including renewable energy, lending, and technology, among others, on 40 Act opinions, 40 Act planning, and requests to the SEC with respect to 40 Act relief. Susan's regulatory expertise also extends to fintech clients operating in the asset management and funds space that are launching or operating emerging financial services products that are web- and app-based. These products include digital and tokenized assets, cryptocurrencies, blockchain and distributed ledger technology (DLT), and various types of investment platforms such as roboadvisory and crowdfunding platforms.
Prior to private practice, Susan was senior counsel at the SEC's Division of Investment Management’s Office of Chief Counsel, providing guidance on a broad array of issues under the U.S. Investment Advisers Act of 1940 and the 40 Act. Early in her career, she served as a judicial clerk to Judge Constance Baker Motley in the U.S. District Court for the Southern District of New York.
