Manny Halberstam is Partner in Simpson Thacher’s Investment Funds Practice. Based in New York, Manny provides investment management regulatory advice to private fund sponsors and other asset management firms, including private equity firms, venture capital firms, hedge funds and fund managers that invest in real estate, infrastructure, private credit, secondaries and digital assets.
Manny has significant experience analyzing the applicability of U.S. investment adviser registration requirements to U.S. and non-U.S. businesses, guiding clients through the SEC registration process and helping clients navigate the ever-changing and increasingly complex landscape of Advisers Act regulation. His areas of focus include SEC marketing regulations, performance track record issues, the SEC custody rule, Form ADV, Form PF, conflicts of interest, related party transactions, expense allocation issues, gift and entertainment issues, “change of control” issues, the SEC pay-to-play rule and placement agent activity oversight, among other areas.
He also assists clients with SEC examinations, mock SEC audits and compliance program development and implementation, including codes of ethics, MNPI policies, information barriers and compliance protocols for addressing emerging areas such as artificial intelligence (AI), ESG and off-channel communications.
In addition to his Advisers Act-related work, Manny regularly counsels clients on Investment Company Act “status” issues that arise in connection with private fundraises, employee investment programs, credit transactions, IPOs and other capital market transactions. He also guides clients on compliance with Securities Act private placement rules and non-U.S. offering rules. Additionally, Manny provides investment management regulatory advice in connection with asset management M&A transactions.
Prior to joining Simpson Thacher in 2018, Manny worked as a securities regulation compliance consultant at ACA Compliance Group, where he led and participated in compliance program reviews and mock SEC audits of private fund sponsors, helped develop and update compliance policies and procedures, assisted with Form ADV filings, reviewed marketing materials for compliance with SEC regulations, updated fund sponsors about regulatory trends and developments and maintained a database of SEC examination deficiencies. During his time at ACA, Manny authored various articles on investment management regulation topics, including the first article to be published about the implications of the SEC staff’s 2017 “DAO Report” for RIA employee trading policies relating to cryptocurrencies and other digital assets.
Manny received his J.D. in 2014 from The George Washington University Law School with honors, where he was a Notes Editor for The George Washington International Law Review, a member of The George Washington Moot Court Board and President of the Jewish Law Student Association. He received his B.A. from Brandeis University in 2010. He is admitted to practice in New York.