Thoreau Bartmann is a partner and member of the Asset Management and Investment Funds practice. He has more than 20 years of experience as an investment management lawyer at the United States Securities and Exchange Commission (SEC), included serving as co-chief counsel of the Division of Investment Management. He has a deep well of experience on a wide array of asset management issues, and advises clients on regulatory, enforcement, and compliance matters. He brings with him a knowledge of rulemaking, cross-border regulatory engagement, digital assets, AML, private fund issues, and fund governance, as well as an intimate understanding of the Investment Advisers Act, the Investment Company Act, and securities enforcement. At the SEC, he also served as a branch chief for the rulemaking office, where he led the adoption of the Adviser Marketing Rule and the Fund Fair Valuation and Liquidity rules. He also held the position of senior policy advisor to the head of the asset management unit of the Division of Enforcement, evaluating and providing guidance on asset management cases brought to the Commission.
With a career as a trusted adviser to commissioners, senior executives, and global regulators, he is equipped to guide clients through new rules, exams, and investigations. He has the breadth and depth of a career rooted in rulemaking perspectives and enforcement pragmatism. Based in Washington, DC, his regulatory, policy, and enforcement insights can serve as clear and actionable guidance of the regulatory landscape to asset managers, registered funds, private funds, and fintech innovators.
Most recently, Thoreau served as senior policy adviser of the Asset Management Unit (AMU) at the SEC, where he advised on enforcement actions involving investment advisers and funds, including fiduciary duties, conflicts of interest, private funds, disclosure, and CCO liability. There he also evaluated and provided input on rulemaking and policy issues impacting enforcement strategy, guided investigations, participated in Wells conferences, and development training for the AMU.
As the co-chief counsel of the Division of Investment Management, Thoreau led a team of over 30 chief counsel lawyers who were responsible for providing guidance on all aspects of investment company, ETF, and adviser regulation and compliance. In that role, he provided legal advice to commissioners and senior staff in other Divisions, issued guidance on a wide range of topics, oversaw fund and ETF registration reviews, compliance program assessments, and provided legal advice on requests for exemptive relief.
He also served as the Division’s lead on all digital asset and crypto matters, where he drafted guidance on state trust custody issues, and acted as liaison to the commission’s crypto task force; supervised the Division’s enforcement and examination liaison office; managed the Division’s legislative, regulatory, and international affairs functions; and was responsible for all AML issues and advised treasury in developing adviser AML rules.
Previously, he served as the branch chief and senior counsel, as well as senior special counsel, where he was primary drafter and lead for a variety of significant investment company and adviser rulemakings, including the rules on adviser marketing, fund liquidity, fund fair valuation, money market funds, Reg S-P, ETF Research, and many others.
- Recipient of the Chair’s International Award, 2024
- Recipient of the Investor Protection Award, 2021, 2023, 2024
- Recipient of the Chair’s Honorary Award for Excellence, 2015, 2022
- Recipient of the SEC’s Law and Policy Award, 2015, 2017, 2021
- Recipient of the Martha Platt Award, 2018
- Lecturer on Securities Regulation: Mutual Funds and Advisers at the Catholic University of America, Columbus School of Law
- FIA-SIFMA AMG Asset Management Derivatives Forum, "Growing Access to Private Markets: Opportunities and Remaining Challenges," Austin, TX, 2026
- Speaker, K&L Gates 2026 ETF Think Tank Boston: Opening Remarks, Boston, MA, 2026
- Speaker, Financial Stability Board Senior Supervisor’s Workshop, "Open-End Fund Liquidity Guidance Implementation," Basel, 2025
- Speaker, Investment Advisers Association (IAA) Compliance Conference, "General Session on New Adviser Anti-Money Laundering Rules," Washington DC, 2025
- Speaker, IAA Marketing Working Group, "New Adviser Marketing FAQs," Virtual, 2025
- Speaker, US SEC Division of Investment Management Conference on Emerging Trends in Asset Management, "Global Regulatory Perspective," Washington DC, 2023-2024
- Speaker, International Bar Association (IBA), "Global Challenges and Opportunities for the Asset Management Industry," Boston, 2024
- Speaker, George Washington School of Law, "The Role of Regulators," Washington DC, 2024
- Speaker, IAA Legal and Regulatory Committee, "Chief Counsel’s Office and Marketing Rule Update," Washington DC, 2021-2024
- Speaker, IOSCO Committee Five, "Fund Valuation Roundtable," Hong Kong, 2023
- Speaker, Catholic Law School, "Securities Law Developments Conference," Washington DC, 2023
- Speaker, Association of the Luxembourg Fund Industry, " FSB/IOSCO Panel," Luxembourg, 2023
- Speaker, The Investment Association Annual Conference, " The Regulatory Agenda", London 2023
- Speaker, IBA Conference on Globalization of the Investment Fund, " Supervisor’s Panel," NYC, 2023
- Speaker, IAA Compliance Conference, " General Session on Marketing Rule," Washington DC, 2023
- Speaker, SEC Regulation Outside the US, " CCO and Exam Workshop," London, 2021-22
- Speaker, PLI’s SEC Speaks, " IM Update," Washington DC, 2022
- Speaker, ICI and EFAMA, " SEC Priorities," Washington DC, 2022
- Speaker, Financial Markets Association, " Securities Compliance," Virtual, 2022
- Speaker, Gaim Ops Connect, " The New Adviser Marketing Rule," Virtual, 2021
- Speaker, The Investment Company Institute General Membership Meeting, " Advertising Compliance Developments," Washington DC, 2020
- Speaker, Institutional Investor Winter Roundtable, " SEC Rulemaking Initiatives," NYC, 2020
- Speaker, Consumer Federation of America, " Adviser Marketing," Virtual, 2020
- Speaker, IAA Compliance Conference, " Registered Funds Roundup," Washington DC, 2019
- Speaker, Mutual Fund Director’s Forum Policy Conference, " Fund Liquidity and Distribution," Washington, DC and Boston, 2016, 2018
- Speaker, CCO Outreach, " Fund Liquidity and Derivatives," Chicago and Philadelphia, 2016-2017
- Speaker, Insured Retirement Institute Government, Legal and Regulatory Conference, " Money Market Fund Reform," Washington, DC, 2016
- Speaker, DC Bar Association, " Fund Liquidity Rule," Washington, DC, 2016
- Speaker, NYC Bar Association Committee on Investment Management, " Dinner Panel," NYC, 2016
- Speaker, IMoneyNet Money Market Expo, " Rule 2a-7 Update," Orlando, 2015
- Quoted, SEC guidance maintains ‘thoughtful approach’ to tokenized securities, with.Intelligence, 3 February 2026
- Mentions, "Former SEC Division Co-Chief Counsel Joins K&L Gates In DC," Law 360, 2 February, 2026
- Quoted, "Advisor Advocates Are 'Optimistic' Regulators Will Delay AML Rule," Wealth Management, 18 March 2025
- Quoted, "New regulations on liquidity mismatch to be expected," Paperjam English News, 26 September 2023
- Quoted, "Marketing rule ‘represents balance’ in mandate to back up claims: SEC official," InvestmentNews, 13 March, 2023
- Mentions, "Complying With SEC Marketing Rule: Don’t Say What You Can’t Prove," Planadviser, 14 March, 2023
- Mentions, "DCIIA Courting Retail Investment Advisers," Planadviser, 14 March, 2023
- Mentions, "What the SEC is Scrutinizing in Its Marketing Rule Exams," Plansponsor, 13 March 2023
- Quoted, "SEC emphasizes ‘best interest’ aspect of Reg BI, fiduciary duty," InvestmentNews, 8 September, 2022
- Mentions, "How to survive an SEC exam," Financial Planning, 14 June 2017
- Mentions, "SEC Names New Deputy Director of Division of Investment Management," Lexology, 21 December 2022
