Anne C. Choe
Partner, Asset Management
Anne C. Choe is a partner in Willkie’s Asset Management Department and Chair of Willkie’s DC Associates Committee.
Anne represents investment managers, registered funds and private funds on a broad range of legal, regulatory, and transactional matters. Her experience covers a variety of fund structures, including exchange-traded funds, mutual funds, and private funds (hedge, private equity, private credit and venture capital funds). Anne also regularly counsels family offices and independent boards. She has in-depth knowledge of the various securities and other laws applicable to investment managers and funds, including the Investment Company Act of 1940 and the Investment Advisers Act of 1940. A key aspect of Anne’s practice is representing investment advisers and funds in SEC examination and enforcement matters.
Chambers Global (2021-2024) and Chambers USA (2020-2024) recognize Anne in the area of Investment Funds: Regulatory & Compliance, where she is commended by clients who note that she is “professional and practical, with a keen ability to explain complex regulatory framework applications.”
The Legal 500 U.S. (2023-2024) recognizes Anne as a next Generation Partner in the area of Investment Fund Formation and Management: Mutual/Registered/Exchange-Traded Funds.
Anne was featured by Lawyers of Color in its inaugural “Wonderful Women” list in 2023, which recognizes “dynamic women attorneys working in law firms, companies, and government agencies across the U.S. who show promise in their careers and demonstrate a strong commitment to advancing diversity in the legal profession.”
Anne has significant experience in advising investment management firms in registering with the SEC as investment advisers, as well as advising on exemptions from registration for U.S. and non-U.S. firms. 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.
She routinely counsels clients on compliance with adviser fiduciary duties, marketing rule, custody rule, “pay-to-play” rule, e-communications, as well as the implementation of compliance programs as required by Rule 206(4)-7 under the Advisers Act.
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 of open-end and closed-end funds. 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.
Experience
Prior to joining Willkie, Anne practiced as a certified public accountant auditing mutual funds and hedge funds at PricewaterhouseCoopers LLP.
- Lawyers of Color, Wonderful Women Honorees (2023)
- Chambers USA and Chambers Global (2020-2024) – Investment Funds: Regulatory and Compliance
- The Legal 500 (2023-2024) – Next Generation Partner – Investment Fund Formation and Management: Mutual/Registered/Exchange-Traded Funds
- Member of Women in ETFs
- Board Member of the University of North Carolina Law Alumni Association
- Member of Private Equity Women Investor Network (PEWIN)
- Legal Council on Legal Diversity Fellow (2017)
- Former Member of the New York City Bar Association's Committee on Investment Management Regulation
- Co-Chair of PLI’s Investment Management 2024: Current Issues and Trends (July 2024)
- "SEC and CFTC Adopts Substantial Amendments to Form PF,” The Investment Lawyer (July 2024) (co-author)
- “Be Prepared – A Roundtable Discussion and In-Depth Analysis of the SEC’s Major Rule Changes for Private Funds Advisers” (November 2023, Speaker)
- “Preparing for a Regulatory Deluge” & “New and Notable Focus Areas in SEC Examinations,” IAA 2023 Compliance Workshops (November 2023, Speaker)
- “Final Private Fund Reforms: Issues to Monitor in Preferential Treatment, Adviser Led Transactions and Annual Audit Rules” Private Equity Law Report, (October 2023) (Quoted)
- “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 lead independent board counsel to a number of mutual fund, ETF and interval 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 a private credit manager in an SEC investigation relating to valuation.
- 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