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Willkie Farr & Gallagher LLP

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Education

  • University of North Carolina School of Law, JD, 2009
  • University of Maryland, BS, 2002

Bar Admissions

  • District of Columbia, 2010
  • Maryland, 2009

Anne Choe

Partner

Washington
Willkie Farr & Gallagher LLP
1875 K Street, N.W.
Washington, DC 20006-1238
T 202 303 1285
F 202 303 2285
achoewillkie.com
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Anne C. Choe is a partner in Willkie’s Asset Management Group. She advises a wide range of pooled investment vehicles, including mutual funds, exchange-traded funds (ETFs), private funds (hedge funds, private equity funds and venture capital funds) and their sponsors and investment managers. She has in-depth knowledge of the various securities and other laws applicable to pooled vehicles and regularly counsels investment advisers and family offices on a variety of SEC regulatory filings and compliance matters.

A key aspect of Anne’s practice is advising investment management firms in registering with the SEC as investment advisers. Additionally, she routinely counsels clients on the application of the Advisers Act custody rule, advertising rule, and “pay-to-play” rule, as well as the implementation of compliance programs as required by Rule 206(4)-7 under the Advisers Act.

Anne regularly represents investment advisers and funds in SEC examination and enforcement matters. She also assists clients in connection with internal compliance reviews and investigations, and the development and testing of compliance programs. Anne has significant experience advising on the creation and operation of registered open-end investment companies and ETFs and provides counsel to fund independent boards.

In addition to counseling clients, Anne has built an active fund and investment adviser transactional practice. She is regularly involved in advising on investment management M&A transactions and has recently taken the lead on a number of those deals.

Chambers USA (2020) recognizes Anne as an Up and Coming Practitioner in the area of Investment Funds: Regulatory & Compliance (Nationwide).

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Anne C. Choe is a partner in Willkie’s Asset Management Group. She advises a wide range of pooled investment vehicles, including mutual funds, exchange-traded funds (ETFs), private funds (hedge funds, private equity funds and venture capital funds) and their sponsors and investment managers. She has in-depth knowledge of the various securities and other laws applicable to pooled vehicles and regularly counsels investment advisers and family offices on a variety of SEC regulatory filings and compliance matters.

Selected Significant Matters

  • Serves as co-lead independent board counsel to a number of mutual fund boards.
  • Regularly represents investment managers in launching ETFs.
  • Represents several asset managers in negotiating their advisory agreements with U.S. state pension plans.
  • Represented a private equity firm in an SEC investigation relating to compliance with the SEC’s “pay-to-play” rule.
  • Represented a private equity firm in an SEC enforcement matter relating to fees and expenses.
  • Represented an investment adviser and a registered fund complex in seeking an exemptive order from the SEC.

Prior Experience

Prior to joining Willkie, Anne practiced as a certified public accountant auditing mutual funds and hedge funds at PricewaterhouseCoopers LLP.

Selected Professional and Business Activities

  • Member of Private Equity Women Investor Network (PEWIN)
  • Legal Council on Legal Diversity Fellow (2017)

Selected Publications and Lectures

  • “Form ADV Reporting and Disclosure Amendments: Are You Ready for What Lies Ahead,” Webcast, The Knowledge Group (Jan. 2018) (co-speaker)
  • “Advisers Act Anti-Fraud Rules: Custody, Political Contributions, Solicitors and Proxy Voting Requirements,” Webcast, Investment Adviser Association and NRS Education (April 2017) (co-speaker)
  • “SEC Proposes Changes to Money Market Funds,” The Metropolitan Corporate Counsel (July/Aug. 2013) (co-author)
  • “New Treasury Form SLT Applicable to Investment Managers, Broker-Dealers and Funds,” The Investment Lawyer (Dec. 2011) (co-author)

Publications / News / Events

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