Audrey Wagner
Counsel | Washington, D.C.
Audrey Wagner

Audrey Wagner focuses her practice on diverse investment management, derivative, and commodity matters. Ms. Wagner advises institutional buy-side companies worldwide in the financial services industry, providing clients with product development, transaction assistance, and regulatory, risk management, and compliance counseling.

Ms. Wagner advises U.S. and foreign investment managers on registration, regulatory and compliance matters related to their status as exempt or registered commodity pool operators and/or commodity trading advisors.

Ms. Wagner also advises commodity market participants on Commodity Exchange Act, CFTC regulation, NFA rules and procedures, and futures exchange rules affecting their business. Ms. Wagner assists investment companies registered with the SEC under the Investment Company Act of 1940 with navigating the intersection of the 1940 Act, Commodity Exchange Act and related rules and regulations.

Ms. Wagner regularly advises on U.S. and foreign derivative and commodity trading which includes negotiating and preparing trading documentation for over-the-counter, cleared and exchange-traded derivative contracts, including specialized documentation required for registered investment companies to participate in these markets. In addition, Ms. Wagner negotiates and prepares other specialized agreements such as prime brokerage, lock-up, secured loan and custody agreements. Ms. Wagner has experience reviewing and negotiating China A shares letters, Indian off-shore derivative documentation, as well as other complex securities investments. She also assists institutional buy-side market participants and new exchanges with navigating the CFTC and NFA regulatory landscape when trading in or offering cryptocurrency derivative products (futures, options, and swaps).

In addition, Ms. Wagner advises registered investment companies on 1940 Act, corporate law and SEC regulation issues, as well as provides support for independent board members overseeing such funds. 

Ms. Wagner has been recognized by the Legal 500 (US), which stated that she “garners high praise for her industry knowledge and ease with clients.” She is also listed in IFLR1000 as a Rising Star for investment funds and investment management.

  • Current Developments Affecting the Fund Industry – Implementation of the SEC Derivatives Rule – Financial Services Breakfast Briefing, Palm Desert, CA (March 29, 2022)
  • New Rule 18f-4: Registered Funds' and BDCs' Use of Derivatives Part 1 and Part 2 — Dechert LLP, Webinar Series (March 23 & 25, 2021)  
  • SEC Modernized Regulatory Framework For Leverage & Derivatives Use By Registered Funds & BDCs — Co-hosted by Dechert and Société Générale, Webinar (March 3, 2021)
  • Asset Managers’ Use of Derivatives in Stressed Markets — Dechert LLP, COVID-19 Coronavirus Business Impact Webinar (March 27, 2020)
  • Derivatives Update: Key EU and U.S. Considerations — Dechert LLP, Webinar (July 11, 2019)
  • Legal & Compliance 2019 — Managed Funds Association, New York, NY (April 24, 2019)
  • 10 Years After the Financial Crisis: Trends in U.S. Regulation of Funds and Asset Managers — EFAMA Investment Management Forum, Brussels, BE (November 8, 2018)
  • CFTC and NFA Ongoing Compliance in a Changing Regulatory Environment Seminar — Dechert LLP, Webinar (September 12, 2017)
  • Developments in Derivatives Regulation — 2016 San Francisco Symposium, San Francisco, CA (November 9, 2016)
  • Advanced Topics in CFTC and NFA Ongoing Compliance — Dechert LLP, London, UK (May 10, 2016)
  • Dodd-Frank and U.S. Regulatory Reform Initiatives Affecting European Asset Managers — EFAMA  Investment Management Forum, Brussels (November 5, 2013)
  • Form CPO-PQR: Legal, Compliance and Operational Issues for Investment Advisers and Commodity Pool Operators — Dechert LLP, Webinar (November 19, 2012)
  • Fundamentals of CFTC Registration: What Asian Fund Managers Need to Know — Dechert LLP, Webinar (August 22, 2012)
  • Fundamentals of CFTC Registration and Compliance: What Private Fund Managers Need to Know — Dechert LLP, Webinar (June 20, 2012)
  • Asset Management Developments — Futures Industry Association's 34th Annual Law & Compliance Division Conference on the Regulation of Futures, Derivatives and OTC Products, Baltimore, MD (May 11, 2012)


Services Industries
    • University of Virginia, B.A., 2003
    • University of Virginia School of Law, J.D., 2006
    • District of Columbia
    • Virginia