Investment Advisers, Commodity Trading Advisors and Institutional Investors

Sullivan partners have represented investment advisers regulated under federal and/or state law, CFTC-regulated commodity trading advisors, bank-affiliated advisers, and investment advisers affiliated with insurance companies. Our investment advisory clients have included advisers sponsoring registered investment funds, unregistered investment funds and offshore funds, and advisers providing advice only through separately managed accounts. They have included managers offering quantitative investment strategies, automated investment solutions (robo advisers), Environmental, Social, and Governance (ESG)-focused products, as well as Smart Beta-ETF strategies. They also have included non-U.S. investment managers offering U.S. and non-U.S. investment funds to U.S. investors, and managers delegating investment advisory services.

Our work for our clients includes assistance on regulatory matters, compliance matters, SEC and CFTC/NFA examinations, enforcement matters, preparation and negotiation of investment advisory and sub-advisory agreements, cybersecurity, and client privacy matters, as well as trading and settlement.

We also have represented family offices on regulatory matters, and institutional investors (including private pension plans) making investments in alternative investment funds.

Representative Client Work

• Advising an Australian investment manager on offering non-U.S. funds to U.S. investors
• Advising a real estate investment manager on compliance with the U.S. Investment Advisers Act
• Advising a U.S. hedge fund/private equity fund manager merging with another investment adviser
• Advising a large multinational investment management firm in a comprehensive reorganization of its business
• Redrafting and harmonizing forms of investment management agreements for a U.S. investment manager to cover multiple product lines
• Providing advice under the U.S. Investment Advisers Act relating to a sponsor of a website providing portfolio stress testing to retail investors' portfolios
• Assisting a U.S. investment manager create a cash management program investing in insured deposit accounts
• Drafting compliance policies and procedures for mid-sized real estate investment manager
• Advising a multi-billion dollar family office on its investments in hedge funds and private equity funds
• Representing a European bank in Madoff-related litigation