Schiff Hardin has bolstered its investment management and financial services practices with the hiring of a lawyer from a competing firm.
Domenick Pugliese, who previously practiced law at Paul Hastings, joins Schiff Hardin’s New York office as a partner. Prior to working at Paul Hastings, Pugliese served as deputy general counsel at Alliance Mutual Funds and as an in-house lawyer at Prudential Mutual Funds. His clients include investment advisors, investment managers, and independent directors of mutual funds. It is the latter whom Pugliese principally represents.
In a discussion with IFLR1000, Pugliese described substantial changes to the roles and responsibilities of independent directors. These roles and duties have grown increasingly complex over the years, and the complexity continues to build as the Securities and Exchange Commission imposes significant new requirements on market players. In just the last three months, the SEC has come out with three major rule proposals.
“One of these is a liquidity management rule that would require all funds to create liquidity management programs and would place on directors the responsibility to approve and periodically review those programs. That is something that has never been done with directors before. The second is a proposed rule on funds’ use of derivatives. It imposes on boards the responsibility to adopt a derivatives risk management program and to monitor that program. The third example, again within the last three weeks, is an investment management guidance piece which is different from the proposed rule. It sets forth the views of the SEC with respect to the role of boards in approving and reviewing service fees paid to third-party record keepers or broker dealers,” Pugliese said.
“This intensified scrutiny has been going on for a number of years now, but these are the latest three examples,” he added.
Pugliese holds a J.D. from George Washington University Law School and a B.S. from the State University of New York, Binghamton.