Stephen T. Cohen

stephen-cohen

Stephen T. Cohen

Partner

Washington, D.C. | 1900 K Street, NW, Washington, DC, United States of America 20006-1110
+1 202 261 3304 | +1 202 261 3333

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

Mr. Cohen counsels mutual 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. Since 2013, he has been an active member of the National Society of Compliance Professionals (NSCP), an organization that supports compliance officials in the securities industry.

Mr. Cohen also counsels mutual fund boards and independent board members. He regularly attends mutual 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 2014.

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.

Education
  • University of Florida, B.S., 2000, with Highest Honors
  • American University Washington College of Law, J.D., 2003
Admissions
  • District of Columbia
  • Maryland
Memberships
  • Advisory Board, iMoneyNet
Speaking Engagements
  • Regulatory Update: Liquidity — Crane’s Bond Fund Symposium, Philadelphia, PA (March 26, 2019)
  • Interval Fund Nuts and Bolts — The Rise of Interval Funds: They're Back and Better Than Ever, New York, NY (December 4, 2018)
  • CCO Forum — Presented by U.S. Bancorp Services, New York, NY (October 23, 2018)
  • Regulatory Issues: Repo, SEC Sweeps, European — Crane’s Money Fund Symposium, Pittsburgh, PA (June 25-27, 2018)

    Speaker, "Regulatory Issues: Repo, SEC Sweeps, European” conference covered a variety of topics related to money funds. 
  • U.S. Bancorp Fund Services' Annual Client Conference, Milwaukee, WI (June 6-8, 2018)

    Speaker, "Liquidity Risk Management and Reporting Modernization Readiness” panel discussed industry readiness for implementation of liquidity risk management programs. In addition, it examined new filings by the U.S. Securities and Exchange Commission.
  • 29th Annual Conference on the Globalisation of Investment Funds — Presented by the International Bar Association, New York (May 13-15, 2018)
  • Regulatory Update: Form N-PORT, Liquidity — Crane Data’s Bond Fund Symposium, Los Angeles (March 23, 2018)

    Speaker., "Regulatory Update: Form N-PORT, Liquidity” conference covered a variety of topics related to bond funds and offer fixed income portfolio managers, bond investors, issuers, dealers and service providers a concentrated educational experience, as well as an informal networking opportunity. 
  • FinTech: The Future is Now — 2017 Los Angeles Investment Management Symposium, Los Angeles, CA (November 29, 2017)
  • Registered Funds — 2017 Los Angeles Investment Management Symposium, Los Angeles, CA (November 29, 2017)
  • Registered Funds Track — 2017 San Francisco Investment Management Symposium, San Francisco, CA (November 28, 2017)
  • CCO Forum — Presented by U.S. Bancorp Services, Atlanta, GA (November 16, 2017)

    Speaker, "CCO Forum" panel on liquidity and report modernization.
  • Liquidity Risk Management, Derivatives and the SEC's New Rules — 2017 Cohen Client Conference, Nashville, TN (October 13, 2017)

    Speaker, "Liquidity Risk Management, Derivatives and the SEC's New Rules" panel discussed the sweeping changes enacted by the SEC in regards to fund’s liquidity and risk management responsibilities. The panel also dove into the aspects of the proposed derivative rules and provide an update to the status of that rule-making initiative.
  • Compliance and Regulatory Updates: SEC Modernization and Liquidity Management Rules — Fund Operations and Technology Leaders Summit 2017, New York (October 3, 2017)

    Speaker, "“Compliance and Regulatory Updates: SEC Modernization and Liquidity Management Rules” panel discussed the following topics: Best practices for preparing for Form N-PORT and Form N-CEN; How to construct a compliant liquidity risk management program; How to deal with hurdles relating to “de minimis” cash requirements and the parameters to qualify as an in-kind ETF; How to respond if the SEC wants to question one’s operational procedures and reporting efforts; and How and why operations professionals should prioritize their relationship with the firm’s CCOs and compliance managers.
  • The Emerging Regulation of Robo-Advisers: Practical Advice — Dechert LLP, Webinar (May 2, 2017)
  • Regulatory Update: Liquidity, Fees & More — Crane's Bond Fund Symposium, Boston (March 23-24, 2017)

    Speaker, "Regulatory Update: Liquidity, Fees & More” conference covered a variety of topics related to bond funds and it offers fixed income portfolio managers, bond investors, issuers, dealers and service providers a concentrated educational experience, as well as an excellent and informal networking venue. 
  • New Money-Fund Rules in Place: How's it Going? — 19th Annual Money Market Expo, Orlando, FL (March 8, 2017)

    Speaker, "New Money-Fund Rules in Place: How's it Going? " panel examined the latest economic projections, a myriad of changes affecting cash-management options and the timing for future Fed moves on short-term interest rates. It also discussed the pluses and minuses from the viewpoints of both fund sponsors and investors about the impacts resulting from a substantially-changed money-fund landscape.
  • The SEC's Investment Company Reporting Modernization Rules and Forms: What You Need to Know — Dechert LLP, Webinar (November 30, 2016)
  • Liquidity Risk Management, Derivatives and the SEC's Proposal — 2016 Cohen Client Conference, Chicago (September 9, 2016)

    Speaker, "Liquidity Risk Management, Derivatives and the SEC's Proposal" panel.
  • Implementation of the Remaining Amendments to Rule 2a-7 — 18th Annual Money Market Expo, Orlando (March 7, 2016)

    Speaker, "Implementation of the Remaining Amendments to Rule 2a-7" panel examined the latest round of SEC-mandated money-fund rule changes that are about to take hold, as well as how fund sponsors are realigning their fund lineups to meet the new requirements.
  • The SEC's Investment Company Reporting Modernization Proposal: What You Need to Know — Dechert LLP, Webinar (July 28, 2015)
  • Money Market Fund Reforms and Shareholder Proxy Solicitation Implications — ICI's General Membership Meeting, Washington D.C. (May 6, 2015)
  • Revising Those Investment Guidelines — 17th Annual iMoneyNet Money Market Expo, Orlando, FL (March 11, 2015)

    Speaker, "Revising Those Investment Guidelines" panel provided current information that you need to know about the money markets and money fund reform.
  • The New World of Money Market Funds: The SEC Issues New Rules by Split Vote — Presented by West LegalEdcenter, Webinar (September 18, 2014)
  • Business Law Securities Regulation Committee Meeting — New York State Bar Association, New York (September 17, 2014)

    Speaker, "Business Law Securities Regulation Committee Meeting" panel addressed money market fund reform – the SEC’s recent approval of amendments to Rule 2a-7 and other rules that govern money market funds.
  • Overview of the SEC's Money Market Fund Reform Amendments — Dechert LLP, Webinar (August 14, 2014)
  • Money Market Fund Regulation in the Spotlight — Dechert LLP, Webinar (January 7, 2013)
  • Prospects for Money Market Fund Regulation — Dechert LLP, Webinar (September 13, 2012)