Stephen T. Cohen

Stephen T. Cohen focuses his practice on the investment management industry, primarily representing mutual funds, closed-end funds, and ETFs and their investment advisers and boards with respect to a wide variety of regulatory, compliance and securities law issues.

Mr. Cohen counsels fund clients on all aspects of their operations. He advises mutual funds on developing, organizing and registering new funds under the federal securities laws; complying with state blue sky registration issues; reorganizing and merging funds; preparing shareholder proxy materials; and seeking SEC exemptive orders and other informal regulatory relief.

Mr. Cohen regularly works on fund and investment adviser compliance matters. He prepares and updates compliance policies and procedures. He also assists clients in responding to requests during SEC examinations and other regulatory requests.

Mr. Cohen also counsels fund boards and independent board members. He regularly attends fund board meetings and advises boards on regulatory and corporate governance related matters. He also works with fund boards on procuring and reviewing D&O/E&O insurance policies.

Mr. Cohen has worked on a wide range of matters on behalf of money market funds operating in accordance with Rule 2a-7 under the Investment Company Act of 1940. In particular, he has reviewed securities for eligibility under Rule 2a-7; addressed compliance issues with respect to money market fund holdings; prepared numerous comment letters to the SEC and FSOC on money market fund rule proposals; and presented training sessions to portfolio managers, administrators, board members and others relating to money market fund regulation. He is actively involved in advising money market fund clients on the SEC’s money market fund reforms that were adopted in July 2023.

Mr. Cohen was named as a Rising Star at the Mutual Fund Industry Awards in 2016 and he was recently a finalist for Independent Counsel of the Year.  He has also been recognized in The Legal 500 (US) in the area of mutual/registered funds.