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Portrait of Rachael L. Schwartz
Portrait of Rachael L. Schwartz

Biography

Rachael has over 18 years’ experience counseling registered investment companies (including mutual funds, exchange-traded funds and closed-end funds) and their boards regarding all aspects of the 1940 Act and related securities laws. Rachael counsels registered investment companies and their boards on all relevant matters, including with respect to Section 15(c) contract approvals and renewals, oversight of multi-manager and sub-advisory relationships, disclosure issues, fund governance, ESG matters, cybersecurity and the launch and reorganizations of funds and fund complexes. She also helps clients develop policies and procedures in connection with new SEC rules and regulations, as well as advise independent directors on their duties and responsibilities related to these new rules.

*Rachael is not admitted to practice in Washington, D.C.

Education
  • Washington University School of Law (J.D.)
  • Duke University Fuqua School of Business (M.B.A.)
  • Wellesley College (B.A., cum laude)
Bar & Court Admissions
  • New York
Professional Qualifications
  • American Bar Association
  • New York City Bar Association, Regulation of Investment Management Committee
Awards & Honors
  • Thomson Reuters "Stand-Out Lawyer" (2025)
  • Chambers USA (2019)
  • Recommended by The Legal 500 U.S. (2024)
Representative Matters
  • Serves as Trust and Board counsel to a number of multiple series trusts, providing all services required, including but not limited to, annual fund registration updates, fund reorganizations, proxies, mutual fund to ETF conversions and assistance with implementation of new SEC rules.
  • Serves as Trust counsel to an ETF complex, providing all services required, including but not limited to, all matters relating to the organizational meeting, fund launches, annual fund registration updates, fund reorganizations, proxies, mutual fund to ETF conversions and assistance with implementation of new SEC rules.
Viewpoints
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SEC Proposes New Regulation E-Delivery
On July 16, 2026, the Securities and Exchange Commission (“SEC”) proposed a new rule, Regulation E-Delivery, that would expand the ability of issuers, including registered investment companies, investment advisers, and broker-dealers, to use electronic delivery (“e-delivery”) to satisfy information delivery requirements under the federal securities law.  If adopted as proposed, Regulation E-Delivery would broadly address the e-delivery of “covered information” by “covered entities” to “covered recipients” (each as described further below) and provides the requirements and conditions for the delivery of regulatory information electronically without first obtaining investors’ affirmative consent. The proposed rule is now available for public comment.  Public comments are due by September 21, 2026. Proposed Regulation E-Delivery Currently, many required regulatory disclosures and reports are delivered in paper format, unless the investor or shareholder affirmatively elects otherwise.  The SEC proposed the rule to make e-delivery the default method based on its understanding about investors’ use of and preferences for electronic media and to continue toward a regulatory framework more suitable for the modern era.  If adopted, Regulation E-Delivery would be the SEC’s primary rule addressing e-delivery and would supersede the SEC’s current guidance-based e-delivery framework. As noted above, proposed Regulation E-Delivery would apply to the e-delivery of “covered information” by “covered entities” to “covered recipients.”  The proposing release defines those terms generally as: Covered information: any information required to be delivered to a covered recipient under the federal securities laws. Covered entities: any person that has an obligation to deliver covered information to a covered recipient under the federal securities laws. Covered recipients: any current or prospective customer, client, investor, security holder, counterparty, or similar recipient of information.  The proposed rule does not make any distinction between retail and institutional clients and investors, although the SEC has asked for public comment on this issue. As proposed, Regulation E-Delivery would permit, but not require, covered entities to use e-delivery as the default method of delivery for covered information.  Generally, a covered entity would be able to rely on the proposed rule where: (1) the covered recipient has provided an electronic address; (2) the covered entity has provided a prominent disclosure to the covered recipient that it will send covered information to the electronic address provided; and (3) the covered recipient has not opted out of e-delivery. Under the proposed rule, the permissible method of e-delivery would depend on whether the covered information includes personal financial information (“PFI”).  If covered information does not include PFI, direct delivery to a recipient’s electronic address, either attached or included in the body of an email, would be permitted.  If covered information includes PFI, a covered entity may not deliver this information directly to an electronic address but would instead have to deliver a statement of availability to the recipient’s electronic address, which would include a link to a website where the covered recipient could access the required information. The proposed rule also details other requirements and conditions for satisfying Regulation E-Delivery, including the process for investors to receive paper reports, opt out of e-delivery, and how investors may update their electronic addresses.  The proposed rule also would require covered entities to adopt and implement written policies and procedures reasonably designed to identify and remediate failed e-delivery, which would include detecting an invalid or inoperable electronic address via bounce-backs or other means.  If a failed e-delivery is identified, the covered entity must promptly take reasonable remediation steps. Additional Observations We note the following: The SEC also is proposing to rescind Rule 30e-3 under the Investment Company Act of 1940.  That rule provides alternative methods for registered investment companies to satisfy their shareholder-report-transmission requirements.  The SEC also is proposing to amend certain rules in Regulations 14A and 14C and Rule 14d-5 under the Securities Exchange Act of 1934, which address the dissemination of proxy materials and tender-offer materials. The proposed rules would not change any timing requirements or regulatory deadlines under the federal securities laws, such that, regardless of the e-delivery method used, the covered entity would be required to deliver the covered information no later than the date by which the information is currently required to be delivered. As noted above, the proposed rules would require entities to adopt written policies and procedures to identify and remediate failed e-delivery.  Registered investment companies and investments advisers likely would have to draft and adopt new compliance policies and procedures to account for Regulation E-Delivery, rather than rely on current rules, in order to ensure that they have the ability to take reasonable remediation steps, including obtaining new electronic addresses or delivering the covered information in paper format until the recipient provides a new electronic address. If the rules are adopted as proposed, investors who currently receive regulatory information in paper format would first receive two paper notices if they would be transitioned to e-delivery, with such notices including the ability to opt out of e-delivery.  The first paper notice would need to be delivered at least 180 days before the transition, with a paper follow-up notice delivered at least 30 days before the transition. The range of regulatory disclosures and reports available for electronic delivery under the proposed rule is broad, including prospectuses, annual and semi-annual shareholder reports, proxy statements, Form CRS disclosures, and Form ADV Part 2 brochures.  For a fuller list of covered information, please see Appendix A below. For More Information This Client Alert has been prepared by John Hunt, a Partner, Rachael Schwartz, a Partner, and Mike Davalla, Counsel, in the Investment Management practice group of the international law firm of Sullivan & Worcester LLP.  For more information, Mr. Hunt may be reached in our Boston office by calling +1 (617) 338-2961 or our London office by calling +44 (0)20 7448 1000, or by email at jhunt@sullivanlaw.com; Ms. Schwartz may be reached in our New York office by calling +1 (212) 660-3069 or by email at rschwartz@sullivanlaw.com; Mr. Davalla may be reached in our Boston office by calling +1 (617) 338-2804 or our Washington, D. C. office by calling +1 (202) 775-2200, or by email at mdavalla@sullivanlaw.com. This Client Alert is provided for general informational purposes only and does not constitute legal advice. Appendix A – Covered Information Under the E-Delivery Proposal Type of Covered Entity Type of Covered Information Investment Companies Fund prospectuses Annual and semi-annual shareholder reports Rule 19a-1 notices Proxy statements and information statements Tender offer statements (for applicable investment companies) Investment Advisers Form ADV Part 2 brochures Marketing and testimonial disclosures Agency cross transaction disclosures Custody rule account statement notices Broker-Dealers Trade confirmations Form CRS disclosures Reg S-AM disclosures Other Issuers Issuer prospectuses Annual reports to security holders Proxy statements and information statements Tender offer statements and solicitation/recommendation statements Offering circulars * As noted in the proposing release, the above list is non-exhaustive, as the definition of “covered information” in the proposed rule may include disclosures not listed here but that may be required under, for example, Regulation Best Interest, as well as disclosure that be required of covered entities in the future under applicable laws and regulations.
SEC Proposes Amendments to Small Entity Definitions
On January 7, 2026, the Securities and Exchange Commission (“SEC”) proposed amendments to the rules that define which registered investment companies, investment advisers, and business development companies qualify as small entities for the purposes of the Regulatory Flexibility Act (RFA).[1] The Proposing Release notes that the amendments would increase the asset-based thresholds used in such definitions and would also provide for a mechanism for future periodic inflation adjustments of those asset-based thresholds.  While the RFA does not mandate any specific regulatory outcome, it is intended to ensure that agencies, such as the SEC, consider the economic consequences of their rules on small entities. Generally, when the SEC adopts a new rule, it has often provided small entities with additional time to come into compliance, which is important because small entities frequently do not have the resources to develop tools in-house to comply with certain rules, and instead must contract with third-party vendors. Even when a new SEC rule only requires additional procedures and an entity does not need to hire an third-party service provider, the additional time to come into compliance can still be helpful.  Overview Proposed Amendments to Rule 0-10 of the Investment Company Act of 1940, as amended (the “1940 Act”) Raising the Net Asset ThresholdThe proposed amendments would amend Rule 0-10 of the 1940 Act to increase the small entity net asset threshold for investment companies from $50 million to $10 billion. The Proposing Release notes that this change would improve the usefulness of RFA analyses by more closely reflecting the population of funds that does not have the same competitive advantages as larger fund groups and would also more closely reflect the population of funds that does not have the same negotiating power as larger fund groups when retaining service providers to perform compliance and operational functions. Group Definitions AmendmentsThe proposed amendments would amend Rule 0-10 of the 1940 Act to replace the term “group of related investment companies” with “family of investment companies” as the term is used in Item B.5 of Form N-CEN. “Family of Investment Companies” means, except for insurance company separate accounts, any two or more registered investment companies that: (1) share the same investment adviser or principal underwriter; and (2) hold themselves out to investors as related companies for purposes of investment and investor services. Proposed Amendments to Rule 0-7 of the Investment Advisers Act of 1940 (the “Advisers Act”) The Regulatory Assets Under Management (“RAUM”) ThresholdThe proposed amendments would amend Rule 0-7 of the Advisers Act to increase the small entity RAUM threshold from $25 million to $1 billion. The Control Relationship ThresholdThe proposed amendments would amend the Control Relationship Threshold in accordance with the changes to the RAUM Threshold in Rule 0-7 of the Advisers Act, from $25 million to $1 billion. Form ADV AmendmentsThe proposed amendments would amend certain Form ADV instructions to update the definition of a small adviser as noted above.  Periodic Future Adjustments The proposed amendments would also provide for future inflation adjustments to the asset thresholds every 10 years for both Rule 0-7 of the Advisers Act and Rule 0-10 of the 1940 Act.  The Proposing Release requests comments on various questions the SEC has laid out with respect to these proposals, as well as whether the SEC should also  amend the total assets threshold in Rule 0-7 of the Advisers Act, which is not part of the current proposed amendments.     [1] Release IC-35864, amendments to the “Small Business” and “Small Organization” Definitions for Investment Companies and Investment Advisers for Purposes of the Regulatory Flexibility Act (January 7, 2026) at https://www.sec.gov/files/rules/proposed/2026/ia-6935.pdf (“Proposing Release”).
News
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Sullivan & Worcester Attorneys Recognized as Thomson Reuters Stand-Out Lawyers
Sullivan & Worcester is pleased to announce that eight of our attorneys have been named Thomson Reuters "Stand-Out Lawyers" for 2025. This recognition is based on direct nominations from senior legal buyers worldwide who identify the lawyers that have made a lasting impact through their exceptional service, expertise and client commitment. Lawyers are recognized for their ability to enhance client satisfaction, increase client advocacy, expand market share, foster engagement and contribute to overall profitability. The following Sullivan attorneys have been recognized: Domenick Pugliese Douglas Stransky Geoffrey Wynne Gerry Silver Michael Dyson Rachael Schwartz Truman Bidwell Sam Fowler-Holmes
Sullivan Earns Top Rankings in the 2024 Edition of The Legal 500 United States
Boston, MA – Sullivan is pleased to announce that its practice groups and attorneys have been highly ranked and recommended in The Legal 500 United States 2024. Peers and more than 300,000 corporate counsel have been surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings in The Legal 500 United States 2024: Leading Lawyers: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Lewis Segall - M&A: Middle-Market (Sub-$500m) Douglas Stransky - International Tax Joel Telpner - FinTech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Nicole Crum - Mutual/Registered/Exchange-Traded Funds Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance A mix of public companies, private companies, trusts and not-for-profit organizations turn to the team at Sullivan & Worcester for its ability to offer advice on a host of matters, including ongoing legal counsel to investment funds and general ongoing board counselling. Nicole Crum focuses on the representation of boards and board committees, regularly advising them on all aspects of governance and compliance, while Boston’s Howard Berkenblit handles ongoing corporate governance and disclosure matters, stock exchange listing standards, and Sarbanes-Oxley Act and Dodd-Frank Act compliance. Both David Leahy and David Mahaffey are frequently engaged by independent directors, mutual funds, exchange-traded funds and closed-end funds. Dispute Resolution/General Commercial Disputes Attorneys at Sullivan & Worcester routinely undertake the full spectrum of complex business-critical disputes, with standout expertise in securities litigation, insurance coverage disputes, and sector-specific disputes arising out of the tech and cryptocurrency spaces. Gerry Silver and Patrick Dinardo jointly chair the practice group out of New York and Boston, respectively. Silver’s practice focuses on software, licensing, internet and IT outsourcing, and implementation disputes; Dinardo is mostly engaged in complex contract, trust, real estate, and insolvency-related matters. Other important contacts within the group include fellow Boston-based practitioner Laura Steinberg who is an expert on complex regulatory and fiduciary issues. Employee Benefits, Executive Compensation and Retirement Plans: Design Sullivan advises on a range of tax-related issues which arise from employment and benefit matters. David Guadagnoli leads the practice. Described as "an exceptional resource" for clients, Guadagnoli has strong experience in advising on tax-qualified retirement plans, particularly 401(k) and 403(b) plans. Amy Sheridan focuses on regulatory and tax requirements for welfare plans. Sheridan’s recent work includes assisting household employers with tax-qualified contribution plans. Both individuals are based in Boston. Clients commented: "Attorneys at Sullivan & Worcester bring years of experience as well as their forward focus on regulatory development to ensure that the client has the right information to execute business goals while remaining compliant." "Very well up to date on current topics. Great research abilities and very responsive. Good communication and project management." "The team provides flexible support and has been very accommodating to meet challenging deadlines. They do this as a team, ensuring that the clients make successful decisions." Environment: Transactional In the environmental sector, Sullivan & Worcester is known for handling a range of due diligence and regulatory work in REIT transactions, where the team is actively involved in land use, zoning and environmental permitting issues. From the Boston office, Victor Baltera advises on regulatory compliance and permitting matters related to environmental law and land use. Boston-based Gregory Sampson recently joined the team from Womble Bond Dickinson, bringing new expertise in the development of contaminated properties and renewable energy and infrastructure projects. FinTech Lauded by clients for its "unique blend of traditional expertise and forward-thinking adaptability," the New York-based practice often advises policymakers on regulatory FinTech matters and is well-regarded for its broad blockchain expertise. Joel Telpner and Natalie Lederman jointly lead the department, the pair of whom are praised for their "deep expertise, innovative thinking, and client-centric approach." Lederman is also experienced in consumer finance transactions and regulatory digital asset matters, notably token generation events. Scott Kaufman is highlighted for his capabilities in private and public securities offerings and SEC regulation matters, while in Boston, Douglas Stransky is well-equipped to advise clients on the tax aspects of cryptocurrency. Amy Zuccarello advises borrower and creditor clients on distressed transactions, bankruptcy, and out-of-court restructurings. Client testimonials include: "They are very well-versed in cryptocurrency US laws, rules, and regulations so their counsel has been valuable in product development." "Since they are very knowledgeable, it makes interacting with them and discussing ideas easy and free flowing." "Sullivan & Worcester LLP distinguishes itself through its unique blend of traditional expertise and forward-thinking adaptability. This firm is particularly notable for its deep involvement in innovation, including investment management, blockchain technology, and other emerging technologies." Investment Fund Formation and Management: Private Equity Funds (Including Venture Capital) The firm represents private investment fund sponsors and investors as well as venture capital firms on the formation and registration, maintenance and liquidation of private investment funds, covering diverse asset classes, with a notable specialism in real estate funds. A trio of practitioners oversee the practice: Nicole Rives, who primarily works with institutional investors and asset management departments of insurance companies on investment related matters; Lewis Segall, whose broad practice covers equity and debt financings, joint ventures and M&A; and John Hunt who advises across diverse asset classes and handles regulatory and compliance issues. William Hanson supports the team and is praised by clients as being "experienced, well-informed and commercial." Other key lawyers include Johanna Colpritt and Emily Goldschmidt. Testimonials from clients include: "We deal primarily with Will Hanson on LP portfolio secondaries. He is experienced, well-informed and commercial. Will is responsive and moves deals forward." Land Use/Zoning Life science and laboratory, office, mixed-use, market rate housing, student housing and affordable housing projects, among others, comprise much of the deal flow seen by the rapidly expanding practice group at Sullivan & Worcester. The group represents a client portfolio that includes some of the most active developers in the greater Boston area on complex permitting, land-use, and environmental law mandates. Ashley Brooks serves as practice co-leader, whilst Victor Baltera counsels clients on regulatory compliance and permitting matters. M&A: Corporate and Commercial: Venture Capital and Emerging Companies Sullivan's emerging businesses with equity and debt financings, tech license negotiations, IP protection, and liquidity solutions. The firm represents venture capital entities and angel investors focusing on early-stage investments in sectors spanning the software, telecoms, therapeutics, and fintech industries. Utilizing its Tel Aviv office, the team supports Israeli tech companies in venture capital fundraisings, establishing joint ventures, and US stock exchange listings. Co-heading the practice from New York, Scott Kaufman brings "exceptional legal expertise" to the fintech and blockchain spaces. Lewis Segall, based in Boston and also leading the team, advises companies on M&A, financings, and joint ventures. Other key lawyers include Benjamin Armour and Michael Student. Clients noted: "Their expertise is exceptional, they are swift in their response to your needs, and go above and beyond for their clients." "Scott Kaufman has become an invaluable asset to our companies as well as a friend. He is not just our attorney, but cares about our business and always goes the extra mile to bring value to the relationship. We appreciate his exceptional legal expertise and quick response to our needs." M&A: Middle-Market (Sub-$500m) Sullivan has established itself as a key middle-market firm for seller clients across a diverse set of industry sectors, including fintech and gaming. The team is also known on the market for its ability to handle public-to-public mergers. In Boston, team heads Lewis Segall and Benjamin Armour spearhead the firm’s offering. The latter is a key contact for transactional work involving private companies, while the former is regularly called upon by financial institutions to advise on financing matters and investments. Also in Boston, Avi Rao's expertise encompasses internal reorganizations and restructurings, while New York-based Natalie Lederman is singled out for her knowledge of regulatory issues relating to blockchain and digital assets. "The firm has a breadth of knowledge and resources to tap into to assist us in a variety of matters. They are skilled at simplifying complex situations and presenting the pros and cons of each so that we can make informed decisions." "Lewis Segall demonstrates a strong understanding of the matters we have presented to him. He helps us to think through the complexities of each situation in the context of the other aspects of our business." Mutual/Registered/Exchange-Traded Funds Sullivan has extensive experience advising independent directors and trustees of investment management firms, with the establishment and registering of new funds, including but not limited to exchange traded funds, variable retail and insurance open- and closed ended funds. The investment management team is also frequently engaged as fund counsel in relation to compliance and shareholder matters and board advice. David Leahy and David Mahaffey jointly lead the practice from the firm's Washington DC location, with the former advising clients on the Investment Company Act of 1940, the Investment Advisers Act of 1940, the Securities Act of 1933 and the Securities Exchange Act of 1934, while the latter specializes on federal securities law, for a whole host of registered funds clients. Nicole Crum is another key name in Washington DC and works with boards and board committees on staying compliant with SEC regulations and through government and internal investigations, while John Chilton is well versed in registered fund transactions, and Domenick Pugliese counsels independent directors of mutual funds, ETFs and variable annuity trusts. Rachael Schwartz was promoted to partner in January 2023. Testimonials from clients include: "Experience in 1940 Act registered funds. Experience in working with independent trustees. Experience in practicing before the SEC. Collaborative style and exceptional people including diversity." "The attorneys we deal with are very knowledgeable and experienced. They listen carefully and provide solid and practical advice." "David Mahaffey – David is very experienced in this area. He is responsive, timely and helps us seek practical solutions to issues." Real Estate With roots in Boston, Sullivan's real estate development group handles an array of single and portfolio transactions, leasing, and permitting matters for developers, private equity funds, REITs, and government agencies, among others. Noted for its affordable housing and community development sub-group alongside its environment and natural resources group, the practice has experience across a wide stroke of asset classes that includes multifamily and industrials as well as hospitality and life sciences. Ashley Brooks leads the real estate group with experience covering development and finance, including the likes of workouts, construction loans and fund formation. Transactional lawyer John Steiner, director of Sullivan's real estate department, is noted for his skill advising REITs and foreign investors as well as for his experience in the senior housing sector. Karen Kepler is another key member, mentioned for her expertise advising on real estate tax credits among areas like condominiums, air-rights, and ground leases. Real Estate Investment Trusts (REITs) Public and private REITs both benefit from their relationships with the REITs practice at Sullivan & Worcester LLP, which specializes in REIT tax issues, M&A, secured and unsecured financings, and preferred and common equity offerings. Ameek Ashok Ponda is a director in the tax department and is an authority on REIT tax issues and regularly lectures at Boston University. Practice head Angela Gomes is a corporate finance specialist and handles securities matters for REITs. Avinash Rao advises public companies on securities law and represents REITs in M&A, equity and debt financings, and joint ventures. Shu Wei handles equity and debt financing work. Also noted is newly-promoted partner Sarah Wellings who excels in REIT-related tax issues. All aforementioned lawyers are part of the Boston practice. Client testimonials include: "The team I work with at Sullivan is well versed in REIT matters and always extremely responsive." "Sarah Wellings has been a joy to work with. She pays attention to detail, is extremely easy to work with and always provides prompt and valuable guidance as needed." Tax - International Tax The international tax practice has extensive experience in strategic tax planning and implementation for a wide range of multinational corporations including cross-border M&A, restructuring, and global tax controversy. The Boston-based team also has strengths in international taxation matters for individuals, including international trust and estate counselling for high net-worth families and pre-US residency tax planning. Practice head Douglas Stransky has a special focus on domestic clients investing in foreign jurisdictions and has extensive expertise advising clients on the tax implications of multi-jurisdictional cryptocurrency and fintech-related ventures. Lewis Greenwald has considerable experience advising on tax-efficient acquisitions, transfer pricing planning, and US international tax compliance. Eric Rietveld concentrates his practice on the tax planning of REITs, real estate funds, and international tax. Client testimonials include: "Lewis Greenwald stands out as an exemplary member of the team. His expertise and trustworthiness are evident in every interaction. What sets Lewis apart is his exceptional ability to orchestrate collaboration within the team and across the firm, ensuring that clients receive well-rounded and balanced legal advice. His knowledge and skill in navigating complex tax matters are commendable, making him a valuable asset not only to the team but also to clients seeking expert guidance in international tax matters." "The practice is unique in that the people have both a broad base of tax knowledge as well as an In depth knowledge of the key areas of tax that are typically encountered by Multinational Companies. The team also has relationships with many other tax professionals in a just about every jurisdiction in the world where most USA Multinationals operate. These professionals are able to give you a basic foundation for operating in a foreign jurisdiction and the key areas that are different than USA and other Western countries." Tax - U.S. Taxes (Contentious) Sullivan is particularly adept at handling SALT matters and chiefly represents high-profile clients facing tax controversy within Massachusetts. Jointly leading the team are Richard Jones, David Nagle and Daniel Ryan, all of whom are based in Boston. Jones is a SALT expert who has extensive experience working with clients in the technology, retail, and media industries. Nagle, who is a co-managing partner of the firm, additionally covers federal disputes, as does Ryan, who also maintains a non-contentious practice which covers transactional planning. Caroline Kupiec, who also works from Boston, provides key support to clients facing audits and litigation. Tax - U.S. Taxes (Non-Contentious) Sullivan & Worcester's Boston-based non-contentious tax group offers broad expertise to a wide range of clients, from high-net-worth individuals to mutual funds, with a particularly strong reputation for representing REITs. Ameek Ashok Ponda, focusing on corporate M&A structuring, REIT transactions, and cross-border financings, heads the practice alongside Richard Jones, who has extensive experience in corporate, personal income, and sales/use tax matters. International tax practice head Douglas Stransky offers niche expertise in the tax implications of cross-border cryptocurrency and fintech-related ventures. Firm managing partner David Nagle, handling taxable and non-taxable acquisitions, among other issues, is also a key contact. REITs specialist Sarah Wellings, promoted to partner in January 2024, advises on a variety of public and private matters, including those involving data centers, office buildings, and distributed antenna systems. Other key lawyers include Christopher Curtis and Marc Stern. About Sullivan Sullivan & Worcester (Sullivan) is a global law firm with approximately 200 attorneys in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best‑in‑class client service.

Rachael L. Schwartz

July 22, 2026

–Client Alert

SEC Proposes New Regulation E-Delivery

January 20, 2026

–Client Alert

SEC Proposes Amendments to Small Entity Definitions

October 15, 2024

–Publication

As 2024 Closes Out, It's Time to Prepare for Names Rule Compliance

Fund Board Views

September 20, 2024

–Publication

What the SEC Liquidity Risk Management Amendments Entail

Law360

September 3, 2024

–Client Alert

SEC Adopts Amendments to Form N-PORT and Form N-CEN Reporting Relating to Liquidity Risk Management; Issues Guidance on Open-End Fund Liquidity Risk Management Programs

June 10, 2024

–Client Alert

Are the SEC’s Private Fund Advisers Rules Now Dead? No, but they are on Life Support

Sullivan Client Alert

October 5, 2023

–Client Alert

SEC Division of Examinations Issues Risk Alert on Selection Process of Advisers to Examine

Sullivan Client Alert

September 27, 2023

–Client Alert

SEC Adopts Amendments to the Investment Company Names Rule (Rule 35d-1)

Sullivan Client Alert

August 28, 2023

–Client Alert

SEC Adopts Highly Anticipated Private Funds Rules

Sullivan Client Alert

October 31, 2022

–Client Alert

SEC Proposes New Rule Requiring Investment Adviser Oversight of Certain Third Party Service Providers

Sullivan Client Alert

October 28, 2022

–Client Alert

SEC Adopts Modernized Disclosure Framework for Shareholder Reports

Sullivan Client Alert

June 6, 2022

–Client Alert

SEC Proposes Enhanced Disclosures by Investment Advisers and Investment Companies About ESG Investment Practices

Sullivan Client Alert

May 26, 2022

–Client Alert

SEC Proposes Amendments to Rule 35d-1 Under the 1940 Act

Sullivan Client Alert

February 10, 2022

–Client Alert

SEC Proposes New Cybersecurity Rule under the 1940 Act

Sullivan Client Alert

January 4, 2022

–Publication

A Look at 2022: What Fund Boards Can Expect This Year

Fund Board Views

December 14, 2020

–Client Alert

SEC Adopts New Valuation Rule under the 1940 Act

Sullivan Client Alert

December 3, 2020

–Client Alert

SEC Adopts New Rules on Investment Company Use of Derivatives

Sullivan Client Alert

August 21, 2020

–Client Alert

SEC Proposes Modernized Shareholder Reports and Other Disclosures

Sullivan Client Alert

April 27, 2020

–Client Alert

SEC Proposes New Valuation Rule under the 1940 Act

Sullivan Client Alert

March 30, 2020

–Client Alert

SEC Staff Issues Temporary No Action Letter Allowing Affiliated Purchases of Debt Securities Under Section 17(a) of the 1940 Act

Sullivan Client Alert

March 25, 2020

–Client Alert

Additional SEC Exemptive Relief in Response to COVID-19

Sullivan Client Alert

March 16, 2020

–Client Alert

Ramifications of the COVID-19 Outbreak on Open-End Investment Companies

Sullivan Client Alert

March 13, 2020

–Client Alert

Top 4 Questions Fund Boards Should Ask in the Wake of the Coronavirus

Sullivan Client Alert

Biography Viewpoints News

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The U.S. Securities and Exchange Commission (“SEC”) announced on July 7, 2026, the creation of the Retail Fraud Working Group, a new initiative within the Division of Enforcement designed to identify and combat fraud targeting main street investors. The announcement formalizes a priority that SEC Enforcement Director David Woodcock previewed in his May 13, 2026, remarks to the Managed Funds Association Legal & Compliance Conference, reflecting the current Commission’s broader

Events
Basics of Estate and Trust Administration

Molly Depew will present “Basics of Estate and Trust Administration” at the American Bar Association (ABA)’s Skills Training for Estate Planners, a virtual conference taking place September 17–18 and sponsored by the ABA Real Property, Trust & Estate Law Section. The program offers a streamlined, practice-focused introduction to estate planning for attorneys building skills in trusts and estates. Ideal for young lawyers and those transitioning into the field, the course provides

News
Sullivan Highlighted in Law360 Roundup of New York City's Largest Real Estate Transactions

Sullivan & Worcester was featured in Law360 Real Estate Authority's "NYC Real Estate Week In Review," which highlighted the largest New York City real estate transactions recorded during the week. The publication recognized Sullivan's representation of Fattal Hotel Group in its acquisition of the Blakely Hotel, a Manhattan hospitality property located at 136 West 55th Street. The approximately $38.5 million transaction was among the week's largest deals to hit public records.

Viewpoints
Hiring: Add a Colleague, Not a Liability

Hiring a new employee is typically a moment of optimism—and sometimes, the relationship really does go wonderfully for its entire length and ultimately ends on good terms. But when that hope is treated as an assumption, companies make themselves vulnerable. If a client-facing employee does not have a non-solicitation agreement, a business’s customers could be poached. A new employee, hired because of their great industry relationships, might actually have an

News
Sullivan Represents Fattal Hotel Group in Acquisition of The Blakely Hotel in Midtown Manhattan

Sullivan & Worcester represented Fattal Hotel Group, owner and operator of 329 hotels across 22 countries and based in Tel Aviv, in its acquisition and financing of The Blakely Hotel in Midtown Manhattan. The acquisition marks the client's first hotel investment in the United States and is a milestone in its evolution from a leading European hospitality operator into a global hotel group. The acquisition was completed on July 7,

Viewpoints
SEC Proposes New Regulation E-Delivery

On July 16, 2026, the Securities and Exchange Commission (“SEC”) proposed a new rule, Regulation E-Delivery, that would expand the ability of issuers, including registered investment companies, investment advisers, and broker-dealers, to use electronic delivery (“e-delivery”) to satisfy information delivery requirements under the federal securities law.  If adopted as proposed, Regulation E-Delivery would broadly address the e-delivery of “covered information” by “covered entities” to “covered recipients” (each as described further

Viewpoints
Impact of 21st Century ROAD to Housing Act on Institutional Investor Ownership of Single-Family Rental Homes

The U.S. Congress passed the 21st Century ROAD to Housing Act (the “Housing Act”) and presented it to President Trump on June 29, 2026. At midnight on July 10, 2026, the Housing Act became law because the President did not return it to Congress within ten days (Sundays excepted). The Housing Act includes a wide range of housing reforms designed with the goal of making housing more available and affordable.  This alert

News
Upon Review: The 2026 World Cup's Biggest Legal Stories

Ryan Rosenblatt was quoted in Law360's article, "Upon Review: The 2026 World Cup's Biggest Legal Stories," which examines the legal, regulatory and policy disputes that emerged during the 2026 World Cup, including issues involving FIFA's disciplinary decisions, immigration challenges, public art protections and the legal dispute surrounding Gillette Stadium's hosting of World Cup matches. Discussing the agreement reached between FIFA's affiliate Boston 2026 and the Town of Foxborough over security fees

Events
Financing the Future: From Defence to Critical Raw Materials

Geoffrey Wynne will participate in a panel discussion at ITFA's 52nd Annual International Trade and Forfaiting Conference alongside Ailsa McNeil, Director at Texel, and Hernan Mayol, Board Member and Representative of ITFA Americas and Chair of ITFA’s Latin America Regional Committee (LARC). The session, titled “Financing the future: From defence to critical raw materials,” will be moderated by Clarissa Dann, Editorial Director at Deutsche Bank AG.  The session will explore how trade

Events
The Next Generation: Three Emerging Leaders, Three Ideas

Simon Cook, in his role as ITFA's Head of Education, will jointly moderate a Q&A on “The next generation: Three emerging leaders, three ideas”, together with Charlie O'Mulloy, chair of ITFA’s Emerging Leader Committee and Associate Banker at EBRD, at ITFA’s 52nd Annual International Trade and Forfaiting Conference in Split, Croatia on September 9. The Q&A will follow the presentations made by the finalists of the 2026 ITFA Emerging Leader

Viewpoints
SEC Establishes Retail Fraud Working Group to Combat Fraud Targeting Everyday Investors

The U.S. Securities and Exchange Commission (“SEC”) announced on July 7, 2026, the creation of the Retail Fraud Working Group, a new initiative within the Division of Enforcement designed to identify and combat fraud targeting main street investors. The announcement formalizes a priority that SEC Enforcement Director David Woodcock previewed in his May 13, 2026, remarks to the Managed Funds Association Legal & Compliance Conference, reflecting the current Commission’s broader

Events
Basics of Estate and Trust Administration

Molly Depew will present “Basics of Estate and Trust Administration” at the American Bar Association (ABA)’s Skills Training for Estate Planners, a virtual conference taking place September 17–18 and sponsored by the ABA Real Property, Trust & Estate Law Section. The program offers a streamlined, practice-focused introduction to estate planning for attorneys building skills in trusts and estates. Ideal for young lawyers and those transitioning into the field, the course provides

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