Stephen T. Cohen
Partner | Washington, D.C.
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.

  • Money Fund Regulations: 2a-7 Basics & History — Money Fund University, Crane Data (December 19, 2023)
  • Money Fund Reforms: Latest 2a-7 Changes — Money Fund University, Crane Data (December 19, 2023)
  • Navigating the Recent SEC Rulemakings: Money Market Fund Reforms – Mututal Funds Directors Forum, Webinar (September 12, 2023)
  • Navigating the Recent SEC Rulemakings: Money Market Fund Reforms – Dechert LLP, Webinar (August 10, 2023)
  • Industry Swings Back on Swing Pricing  Ignites, Webcast (June 26, 2023)
  • SEC Takes a Swing at New Money Market Fund Reforms — The Mutual Fund Directors Forum, Webinar (March 10, 2022)
  • Money Market Funds: Regulators Primed for Further Reforms — The Mutual Fund Directors Forum, Webinar (July 15, 2021)
  • Handicapping Money Fund Reforms — Crane Data, Webinar (June 17, 2021)
  • Financial Services and Market Volatility in the Time of COVID — 2020 Virtual California Investment Management Symposium, Webcast (October 27, 2020)
  • Regulatory & ESG Money Funds Update — Crane Data's Mini Fund Symposium, Webcast (August 26, 2020)
  • Market Turmoil and Money Funds: What's Ahead — Ignites, Webcast (April 29, 2020)
  • Money Market Funds – Managing Stress — Dechert LLP, Webinar (March 24, 2020)
  • Money Fund Regulations: 2a‐7 Basics — Crane Data's Money Fund University, Providence, RI (January 24, 2020)
  • FinTech 2019 — Presented by the Practising Law Institute, New York (August 12, 2019)
  • 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)
  • Liquidity Risk Management and Reporting Modernization Readiness — U.S. Bancorp Fund Services' Annual Client Conference, Milwaukee, WI (June 6-8, 2018)
  • 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)
  • 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)
  • Liquidity Risk Management, Derivatives and the SEC's New Rules — 2017 Cohen Client Conference, Nashville, TN (October 13, 2017)
  • Compliance and Regulatory Updates: SEC Modernization and Liquidity Management Rules — Fund Operations and Technology Leaders Summit 2017, New York (October 3, 2017)
  • 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)
  • New Money-Fund Rules in Place: How's it Going? — 19th Annual Money Market Expo, Orlando, FL (March 8, 2017)
  • 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)
  • Implementation of the Remaining Amendments to Rule 2a-7 — 18th Annual Money Market Expo, Orlando (March 7, 2016)
  • 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)
  • 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)
  • 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)
    • University of Florida, B.S., 2000, with Highest Honors
    • American University Washington College of Law, J.D., 2003
    • District of Columbia
    • Maryland
    • Advisory Board, iMoneyNet