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William P. Wade

Of Counsel
+1.310.552.5071
Fax +1.310.552.5001
Investment management activities of banks and other financial institutions, with emphasis on unregistered pooled investment vehicles, ERISA fiduciary responsibility, federal and state regulation of fiduciary activities, and related securities law and tax matters.

Professional Background

Mr. Wade advises banks, trust companies, investment advisers, and other financial institutions in regard to the creation, operation, and regulation of investment management products and services for individual and institutional investors. Substantive experience includes federal (Regulation 9) and state-law regulation of fiduciary activities, bank-sponsored common and collective investment funds (“CIFs’), ERISA fiduciary responsibility matters relevant to separately managed accounts and pooled investment vehicles, securities law exclusions and exemptions applicable to CIFs and other unregistered pooled vehicles and activities, and tax matters related to CIFs (e.g., Code and IRS requirements applicable to common trust funds and “group trusts” for employee benefit plans).

Prior to entering private practice in 1988, ten years’ in-house experience with Office of General Counsel of large financial institution, where responsibilities included advising trust and investment management departments and affiliates.

  • Advised financial institutions regarding application of “VCOC” and “REOC” requirements under U.S. Department of Labor (“DOL”) regulations to private real estate fund and potential restructuring options.
  • Advised sponsors of state “auto-enroll IRA” programs regarding relevant federal securities law matters.
  • Obtained initial DOL prohibited transaction exemptions for collective trust fund-mutual fund "conversion" and in-kind redemptions by in-house plans.
  • Obtained initial OCC ruling authorizing national banks to operate closed-end collective investment funds.
  • Advised national and state banks and trust companies with respect to design, documentation, reorganization and termination of single-level, master-feeder CIF complexes.
  • Advised national bank with respect to application of banking and securities law requirements to common trust fund for credit unions.
  • Advised national bank with respect to application of SEC Regulation R to various bank securities activities.