Mark D. Perlow

Mark Perlow Dechert financial services and investment management lawyer San Francisco

Mark D. Perlow


San Francisco | One Bush Street, Suite 1600, San Francisco, CA, United States of America 94104-4446
+1 415 262 4530 | +1 415 262 4555

| vCard | PDF

Mark D. Perlow represents mutual funds, hedge fund managers, fund independent directors, investment advisers, and broker-dealers on a broad range of regulatory and transactional matters. Mr. Perlow has extensive experience structuring, forming and reorganizing mutual funds and hedge funds; preparing and negotiating fund documents and agreements; and assisting clients on adviser and fund mergers, acquisitions, and adoptions. Mr. Perlow has counseled both fund sponsors and fund investors on regulatory aspects of and issues posed by alternative funds, derivatives, short selling, market structure, and exchange-traded funds. He also advises investment adviser and fund sponsors on FinTech matters, including marketplace lending and online investment advice.

Having served as senior counsel in both the SEC’s Office of the General Counsel and the Division of Enforcement, Mr. Perlow has considerable experience with SEC rule-making, submissions, enforcement, examinations and compliance activity. Mr. Perlow regularly assists funds, broker-dealers, and investment managers on agreements relating to regulation and distribution, and represents them before the SEC and FINRA in connection with registration, exemptive applications, no-action and interpretive requests, enforcement actions, examinations, and transactional and disclosure filings. He has also counseled clients on compliance issues regarding the Dodd-Frank and Sarbanes-Oxley Acts.

Mr. Perlow has been recognized as a leading lawyer for registered funds by Chambers USA. The most recent edition stated that he “is an excellent lawyer according to clients, who comment that he has deep expertise in all aspects of investment management law." Past editions stated that he is “technically very capable, very practical, he communicates very well and is very responsive – a high-quality partner." He has also been recognized by The Legal 500 (US) in the areas of mutual/registered funds and alternative/hedge funds, and he is listed in The Best Lawyers in America for mutual funds law. In 2018, Mr. Perlow was named a BTI Client Services All-Star, recognized as one of 326 lawyers nationwide for excellence in client service.

Mr. Perlow is a frequent author and speaker on securities law and investment management topics. Currently, he is an adjunct lecturer at the University of California, Berkeley Law School. Prior to joining Dechert, he served as a partner in the San Francisco office of another international law firm.

  • University of California, Berkeley, A.B., 1986, summa cum laude
  • University of Oxford, M.A., 1988, Newton-Tatum Scholar
  • Yale Law School, J.D., 1991, Executive Editor for the Yale Journal on Regulation, Olin Fellow in Law, Economics and Public Policy
  • California
  • District of Columbia
  • American Bar Association, Committee on Federal Regulation of Securities, Subcommittee on Investment Companies and Investment Advisers, Task Force on Investment Company Use of Derivatives and Leverage, and the Drafting Committee for Comment Letter on Money Market Fund Reform
  • Federal Bar Association
  • Hedge Funds Care, West Coast Committee
  • West Coast ’40 Acts Group
Speaking Engagements
  • SEC Exams — IAA Investment Adviser Compliance Conference 2019, Washington D.C. (March 14-15, 2019) 
  • Compliance for Robo and Digital Advisers — ACA's Fall 2018 Compliance Conference, Scottsdale, AZ (October 3, 2018) 
  • Liquidity Rule Implications for Advisers — ACA Compliance Group’s Spring 2018 Compliance and Performance Conference, Amelia Island, FL (May 10, 2018)
  • Larger Firms: Considerations for Advisers Using Data Analytics in a Compliance Program — IAA Investment Adviser Compliance Conference 2018, Washington, D.C. (March 16, 2018)
  • The Board's Role in Adviser's Strategy — Mutual Fund Directors Forum 2018 Directors’ Institute, Scottsdale, AZ (January 23, 2018)
  • 2017 Fund Directors Conference — Presented by the Independent Directors Council, Chicago (October 24, 2017)
  • Regulatory Changes Impacting Registered Investment Companies and Service Providers —Ascendant Compliance Conference, Napa, CA (October 10, 2017)
  • Financial Firm Spotlight – Enforcement and Regulatory Update and Recent Developments — Securities Enforcement Forum West 2017, East Palo Alto, CA (May 10, 2017)
  • Liquidity Rule — West Coast '40 Act Group Lunch, San Francisco (April 27, 2017)
  • SEC Exams — 2017 IAA Investment Adviser Compliance Conference, Washington, D.C. (March 2, 2017)
  • Private Funds: Continued Focus on Age-Old Practices with Emphasis on Disclosure and Fees — NRS 31st Fall Compliance Conference, Scottsdale, AZ (November 3, 2016)
  • Compliance, Risk & Enforcement Symposium –New York 2016™ — Presented by the Regulatory Compliance Association, New York (November 2, 2016)
  • Regulatory Hot Topics and SEC Initiatives for 2016 — NICSA West Coast Regional Meeting, Los Angeles (October 6, 2016)
  • Advertising & Marketing Lessons Taken from Recent Enforcement Cases — IA Watch: The Full 360° View West, San Francisco (June 9, 2016)
  • Regulation, Operations and Compliance (ROC) – Bermuda 2016™ — Presented by the Regulatory Compliance Association, Bermuda (April 17, 2016)
  • 2016 Investment Adviser Compliance Conference  — A Seminar Provided by the Investment Adviser Association, Washington, D.C. (March 11, 2016)
  • IDC's Fund Directors Conference 2015 — Chicago, IL (October 27, 2015)
  • Conflicts of Interest: Strategies to Address this Examination and Enforcement Priority — IA Watch: the Full 360 Degree View West, (June 12, 2015)
  • SEC Investigations and Priorities Regarding Asset Managers — Securities Enforcement Forum West, (May 13, 2015)
  • Fund Investment Strategies Using Derivatives: Regulatory and Compliance Considerations — ICI Mutual Funds and Investment Management Conference, (March 16, 2015)
  • Cybersecurity and Annual Reviews -Issues and Developments — IAA Compliance Workshop, (December 2, 2014)
  • Mutual Fund Industry Developments — AIMA Seminar, (October 14, 2014)
  • Institutionalizing Risk Management: A View from the Regulators — HedgeWorld West Conference, (October 8, 2014)
  • U.S. and Global Regulatory Changes and Trends — AIMA Seminar, (September 25, 2014)
  • Advertising and Marketing: Keeping Your Firm Compliant — IA Compliance Best Practices Summit West, (June 12, 2014)
  • Selected Advisers Act Anti-Fraud Rules: Custody, Political Contributions, Cash Solicitors and Proxy Voting — NRS Investment Adviser Compliance Symposium, (June 11, 2014)
  • Portfolio Management: Regulatory Compliance Considerations — Southern California Compliance Group, (May 13, 2014)
  • Lessons from SAC Capital: Could It Happen to Your Firm? — CFA Institute Annual Conference, (May 5, 2014)
  • The Rise of Alternative Mutual Funds — West Coast '40 Acts Group Meeting, (April 25, 2014)
  • Broken Windows: A New Era in SEC Enforcement? — ICI Mutual Risk Management Conference, (April 10, 2014)
  • The Future of Shareholder Activism — UC Berkeley Center for Law, Business and the Economy Symposium, (April 4, 2014)
  • Current Issues in Private Fund Marketing — NSCP San Francisco Regional Meeting, (March 13, 2014)
  • Current Issues in SEC Examinations — IAA Investment Adviser Compliance Conference, (March 7, 2014)