Pablo J. Man

Pablo Man is a partner in the firm's Asset Management and Investment Funds practice. Pablo primarily represents investment advisers, registered closed-end funds (including tender offer and interval funds), and private funds (including exchange funds, hedge funds, and funds of one). Pablo’s practice centers on regulatory matters relating to the Investment Advisers Act of 1940. He also brings substantial experience to the formation of pooled investment vehicles both registered and exempt from registration under the Investment Company Act of 1940. Pablo is highly knowledgeable in the application of the Securities Act of 1933 to private investment funds as well as continuously-offered registered closed-end funds offering their interests in private placements, encompassing offerings without and with a general solicitation.

Pablo counsels investment advisers ranging from emerging managers to large global firms on all aspects of their operations, including registration and “status” questions, regulation and reporting, SEC examinations, seeding arrangements, and mergers and acquisitions. Among other things, Pablo guides clients on matters relating to custody, recordkeeping (including electronic records), trading, principal and cross-transactions, best execution, performance advertising, fiduciary duty and conflicts. He also has a significant practice counseling clients with respect to “wrap” and model portfolio programs. 

With respect to registered funds, Pablo acts as fund and independent trustee counsel. His experience includes all aspects of a fund's launch and ongoing operations, including but not limited to matters related to the implementation of a Rule 38a-1 compliance program; the preparation of agendas, resolutions and related materials in connection with board and committee meetings; and the communications with the SEC staff in connection with fund matters. Pablo also has advised clients with respect to exemptive relief, including co-investment and multiclass relief.

In addition, Pablo regularly advises fund sponsors and finders with respect to broker “status” issues, including the so-called issuer exemption under Rule 3a4-1, in connection with offers and sales of fund securities. Pablo also supports broker-dealers in understanding their standard of conduct obligations under Regulation Best Interest and applicable state law.