Bio

He advises investment managers on the design and implementation of compliance policies and procedures, including the code of ethics, personal trading, gifts and entertainment, insider trading, expert networks, best execution, soft dollars, investment allocation, valuation, expense allocation, conflicts of interest, business continuity, cybersecurity and recordkeeping. He also advises private investment funds on SEC registration requirements and available exemptions. David has deep experience in the formation and representation of private funds, advising on offering documentation, investment management agreements, separate account agreements, solicitation agreements, seed capital arrangements, side letters, employment matters, non-compete and non-solicit agreements, non-disclosure agreements, brokerage agreements and service provider agreements. David’s advice draws from a wealth of in-house experience, having served as Chief Compliance Office and senior counsel to multiple SEC registered investment management firms.