Sarah Clinton is a partner in the corporate department and a member of the firm’s investment management group. Sarah’s practice focuses on representing investment advisers and registered investment companies in regulatory, transactional, and compliance matters. She regularly advises clients regarding the establishment, registration, operation, and reorganization of open-end and closed-end fund products and has significant experience in structuring and counseling registered investment companies employing alternative investment strategies. She also provides advice to registered investment advisers with respect to regulatory and compliance issues.
- Represents Blackstone Alternative Asset Management L.P. and the Blackstone open-end and closed-end fund complex on a wide range of matters relating to alternative fund products, including the organization of two liquid alternative multi-manager funds, the operation of a fund of hedge funds, the formation of trading subsidiaries, and advice regarding investment activities, sub-advisory and other service provider arrangements, board matters, and compliance.
- Represents Grantham, Mayo, Van Otterloo & Co., LLC and the GMO mutual fund complex on a wide range of matters, including adviser compliance matters, advice regarding investment activities, the organization of a new trust and new open-end funds, fund disclosure, regulatory filings, and board matters.
- Represents registered investment advisers in connection with compliance with the federal securities laws.
- Advised the Highland Funds on a variety of matters, including day-to-day regulatory advice on open-end and closed-end fund issues, fund reorganizations, exemptive applications, and credit agreements.
- Assisted in the launch of a registered fund of private equity funds.
- Represented private fund advisers in developing Advisers Act compliance programs and in the negotiation of technology licensing agreements and drafting of consulting agreements relating to proprietary quantitative trading systems.
- Assisted creditor steering committee in the restructuring of a multi-billion dollar structured ABS investment vehicle.
- Secured intellectual property assets in two whole company securitizations.
- Co-author, “New FinCEN AML and Customer Due Diligence Regulations Await Mutual Funds,” The Investment Lawyer (August 2017)