Before joining Eversheds Sutherland (US), Tom served as a senior counsel in the Office of Insurance Products in the SEC’s Division of Investment Management, working on investment company registration statements, exemptive applications and no-action letters, and participating in rulemaking projects and investment company examinations. He spent two years as a staff attorney in the Division of Market Regulation. Tom participated in several significant SEC projects, including the October 1987 Market Break Study.
Represented several insurers in developing and obtaining groundbreaking regulatory approvals from SEC and FINRA.
Advised mutual fund trustees on fund oversight.
Counseled life insurance companies on the redesign of registered separate account products.
“I’ve co-authored a number of publications that address issues related to mutual funds and variable and fixed insurance products.”
Legal Alert: SEC investment company filings during government shutdown (January 2, 2019)
The Securities and Exchange Commission (SEC) is subject to the current federal government shutdown due to lack of funding, and generally it will follow its “Operations Plan Under a Lapse in ...
Legal Alert: SEC proposes new variable contract disclosure regime (November 6, 2018)
The US Securities and Exchange Commission (SEC or Commission) recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies ...
Legal Alert: SEC permits internet delivery of investment company shareholder reports-including insurance company separate accounts (June 25, 2018)
The Securities and Exchange Commission (SEC) on June 5, 2018, adopted Rule 30e-3 under the Investment Company Act (the Rule), which permits “notice and access” delivery of investment company ...
Legal Alert: Last call! SEC’s pay ratio rule effective for 2018 proxy statements (January 31, 2018)
The long-awaited pay ratio rule (the Rule), adopted by the Securities and Exchange Commission (the SEC) on August 5, 2015, finally takes effect in 2018.1 The Rule, which is intended to provide ...
Legal Alert: Commenters Generally Support SEC’s Simplified Disclosure Proposals Under Regulation S-K (January 24, 2018)
On January 2, 2018, the comment period ended for proposed amendments (the Proposed Amendments) to certain provisions of Regulation S-K that the US Securities and Exchange Commission (SEC) published ...
Legal Alert: New York Proposes Best Interest Standard for Life and Annuity Sales Alongside NAIC Proposal for Annuities (January 4, 2018)
On December 27, 2017, the New York Department of Financial Services (NYS-DFS), the regulatory authority for the insurance industry in New York, published a proposal (New York Proposal) to add a “best ...
Legal Alert: Reminder: SEC Requires Hyperlinks to Exhibits in Certain Filings Made On or After September 1, 2017 (August 14, 2017)
On March 1, 2017, the Securities and Exchange Commission (the SEC) approved rule changes that are designed to facilitate easier and more efficient access to documents that are listed as exhibits to ...
Legal Alert: SEC Staff Provides Guidance on Disclosure of Sales Load Variations and Filing of New Share Classes in Light of the DOL Fiduciary Rule (January 5, 2017)
I. Introduction On December 16, 2016, the Division of Investment Management (IM) of the Securities and Exchange Commission (SEC) published a Guidance Update (the Guidance) providing guidance on ...
Legal Alert: NAIC Adopts Revisions to Actuarial Guideline 49 (December 16, 2016)
On December 13, the National Association of Insurance Commissioners (NAIC) Executive (EX) Committee and Plenary adopted revisions to Actuarial Guideline 49 (AG 49) with an effective date of March 1, ...
Legal Alert: SEC Adopts Liquidity Risk Management Rules for Mutual Funds and Other Open-End Investment Companies (November 14, 2016)
On October 13, 2016, the SEC approved new Rule 22e-4 under the Investment Company Act of 1940, as amended (the 1940 Act), which will require certain open-end investment companies other than money ...
Modernizing The Variable Contract Disclosure Regime (December 2018)
The US Securities and Exchange Commission recently proposed a new disclosure framework for SEC-registered variable annuity contracts and variable life insurance policies that reflects almost a decade ...
A Compromise on Indexed Universal Life Insurance Visuals (July 7, 2015)
On June 18, 2015, the National Association of Insurance Commissioners Executive Committee/Plenary adopted new Actuarial Guideline XLIX (AG 49), which for the first time sets forth uniform standards ...
Soft Dollars, Investment Adviser Regulation - A Step by Step Guide to Compliance and the Law (2011)
Practicing Law Institute, Third Edition, Volume 1, Chapter 17
SEC Adopts New Soft Dollar Guidelines (September 2006)
Reprinted with permission, Investment Lawyer
SEC Clarifies Meaning of Research and Brokerage in Proposed Soft Dollars Release (January 2006)
Reprinted with permission, The Investment Lawyer
Privately Place VLI Products: Charting The Regulatory Waters (September 2000)
ALI-ABA Conference on Life Insurance Company Products: Current Securities, Tax, ERISA, and State Regulatory Issues
Roundtable on the Role of Independent Investment Company Directors: Issues for Independent Directors of Bank-Related Funds, Variable Insurance Product Funds, and Closed-End Funds (November 1999)
The Business Lawyer, Volume 55, Number 1
Legal, Regulatory, and Accounting Issues (1998)
The Handbook of Stable Value Investments
“Our clients, for the most part, are very compliance oriented. They’re good companies trying to do what is right for their clientele. We’re helping them to achieve their goals, and that’s very satisfying work.”
Fundamental of Mutual Funds and Exchange-Traded Funds Regulation 2012 (June 6, 2012)
Practising Law Institute
Fundamental of Mutual Funds and Exchange - Traded Funds 2011 (June 8, 2011)
Practising Law Institute
Commission Sharing vs. Traditional Soft Dollar Agreements (November 2, 2010)
2010 NSCP National Meeting