P. Georgia Bullitt is a partner in the Asset Management Department and Co-Chair of the Financial Institutions/Regulatory Practice Group, focusing on securities and derivatives trading issues, regulation of broker-dealers, investment advisers and other financial intermediaries, and trade-related documentation. Her experience also includes advice on structured products, regulation of foreign exchange (including questions regarding retail forex), and private banking.
Georgia represents both broker-dealers and registered and unregistered investment advisers in connection with a broad range of regulatory issues, including compliance with the federal securities laws, fiduciary matters, and trading and market practices relating to securities, derivatives and foreign exchange. Her clients include both institutional and retail broker-dealers, traditional money managers, pension plan advisers, mutual fund advisers, alternative managers and commodity trading advisers.
Georgia regularly provides advice regarding a broad range of Dodd Frank and CFTC registration-related issues, including swap clearing, registration of SEFs and SDRs, retail and ECP FX transactions, ISDA DF Protocol, swap reporting, and CPO and CTA registration. She also provides assistance to firms in negotiating bilateral and cleared swap documentation.
Georgia has advised a variety of clients—including advertising agencies, consulting firms, banks, broker-dealers, insurance companies, investment advisers and accountants—on legal and policy issues relating to doing business with and investing in CBD and cannabis companies.
Chambers USA - 2017 named Georgia as a Recognized Practitioner in the area of Financial Services Regulation: Broker Dealer (Compliance). Georgia is also recognized by Best Lawyers in America in the areas of Derivatives and Futures Law and Private Funds/Hedge Funds Law.
Experience
Prior to joining Willkie, Georgia was a partner in the Investment Management and Securities Industry Practice of Morgan Lewis & Bockius LLP. She was also previously an executive director and counsel at Morgan Stanley, where she advised the Institutional Equity, Private Wealth Management, and Retail Divisions, and developed training and policies and procedures addressing a number of different areas of the federal securities laws.
Georgia is a member of the New York State Bar Association.
- Co-Author, “The SEC Adopts Derivatives Rule for Registered Investment Companies and BDCs,” Futures & Derivatives Law Report (February 2021)
- Co-Author, “SEC Staff Issues Guidance on Cloud Storage and Data Security for Broker-Dealers and Investment Advisers,” The Investment Lawyer (September 2019)
- Co-Author, “SEC Proposes Enhancing Requirements Affecting How Brokers and Investment Advisers Deal With Retail Investors,” The Investment Lawyer (August 2018)
- Co-Author, “SEC Staff Addresses Cross-Border Implementation of MiFID II Research Provisions,” The Investment Lawyer (April 2018)
- Co-Author, “Regulation of U.S. Currency Transactions,” Futures & Derivatives Law Report (May 2017)
- Co-Author, "SEC Adopts Regulation Systems Compliance and Integrity," Journal of Investment Compliance (2015)
Credentials
Education
University of Michigan Law School, J.D., 1987 Yale University, B.A., 1982