Anne C. Choe
Partner, Asset Management
Anne C. Choe is a partner in Willkie’s Asset Management Department. 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 compliance matters. A key aspect of Anne’s practice is representing investment advisers and funds in SEC examination and enforcement matters.
Anne has significant experience in advising investment management firms in registering with the SEC as investment advisers. Additionally, she routinely counsels clients on the application of the Advisers Act, marketing rule, custody 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. She also assists clients in connection with internal compliance reviews and investigations, and the development and testing of compliance programs, including with respect to insider trading and information barriers.
Anne’s diverse practice covers 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.
Chambers USA (2022) recognizes Anne as an Up and Coming Practitioner in the area of Investment Funds: Regulatory & Compliance (Nationwide), where she is commended by clients who “rely on her heavily for all things SEC.”
The Legal 500 U.S. (2022) recognizes Anne as a Next Generation Partner in the area of Investment Fund Formation and Management: Mutual/Registered Funds, where she is praised by clients for her “incredible understanding of investment management regulation, especially as it pertains to investment advisers, and brings both significant experience and excellent industry understanding to the issues.”
Experience
Prior to joining Willkie, Anne practiced as a certified public accountant auditing mutual funds and hedge funds at PricewaterhouseCoopers LLP.
- Member of the New York City Bar Association's Committee on Investment Management Regulation
- Member of Private Equity Women Investor Network (PEWIN)
- Legal Council on Legal Diversity Fellow (2017)
- "SEC and CFTC Propose Substantial Amendments to Form PF,” The Investment Lawyer (December 2022) (co-author)
- “SEC Proposes New Rule to Require Investment Advisers to Conduct Additional Oversight of Service Providers,” Harvard Law School Forum on Corporate Governance (12/4/2022) (co-author)
- “Current Developments in Exchange-Traded Funds,” Investment Management 2022: Current Issues & Trends program, hosted by PLI (July 2022, speaker)
- “Liquidity Challenges for Open-Ended Investment Funds - and New Solutions,” 31st Annual Conference on the Globalisation of Investment Funds (May 2022, speaker)
- “Regulatory Developments,” 2021 Independent Directors Council Fund Directors Virtual Conference (October 2021, speaker)
- “Private Equity Compliance Update: Conflicts of Interest, Fees and Expenses, Nonpublic Information, and the New Marketing Rule,” Strafford CLE (February 2021, speaker)
- “U.S. Regulatory Updates” panel, Due Diligence Insights conference, presented by Duff & Phelps (June 2021, Co-panelist)
- “Recent Reminder for Exempt Reporting Advisers,” The Investment Lawyer (Jan. 2019) (co-author)
- “The World of Private Funds – Understanding What’s on the Regulatory Horizon,” Ascendant Compliance Conference (October 2018, speaker)
- Serves as co-lead independent board counsel to a number of mutual fund and ETF 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 obtaining a novel exemptive order from the SEC.
- Represented an investment manager in an internal investigation related to private fund fiduciary matters.
Credentials
Education
University of North Carolina School of Law, J.D. (with high honors), 2009 University of Maryland, B.S. (summa cum laude), 2002
Bar Admissions
Court Admissions
United States Supreme Court, 2019