FacultyFaculty/Author Profile
Joan O Swirsky

Joan O Swirsky

Stradley Ronon Stevens & Young LLP
Philadelphia, PA, USA

Joan Swirsky is a seasoned investment management attorney with a nationally respected focus on money market funds operating under Rule 2a-7 under the Investment Company Act of 1940. Joan authored the definitive guide on the subject area entitled “The Guide to Rule 2a-7 – A Map Through the Maze for the Money Market Professional.” The book is so well respected that even industry regulators have ordered copies. Joan, one of the foremost practitioners and thought leaders in legal issues concerning money market funds, is widely quoted in the national press. She is highly regarded for her ability to clarify complex provisions in jargon-free layman’s terms, whether providing detail for compliance personnel or a broad overview for a fund board.

Money market fund projects Joan has handled include:

  • reviewed securities for eligibility under Rule 2a-7 as money market fund investments
  • advised issuers on the structure of Rule 2a-7-eligible securities
  • addressed troubled holdings in money market portfolios, including related communications with the fund board, the public and the SEC staff (such as seeking no-action relief)
  • sought relief from or advice of regulators regarding interpretative questions under money market fund regulation
  • developed and reviewed money market compliance checklists and procedures
  • advised regarding responses to SEC examinations and inquiries relating to money market funds
  • advised regarding SEC enforcement proceedings involving money market funds
  • presented training sessions to portfolio personnel, board members and others relating to money market fund compliance
  • handled day-to-day portfolio compliance issues for money market fund
  • Projects relating to investment company work include:

Projects relating to investment company work include:

  • drafted registration statements and other disclosure documents
  • responded to SEC staff examinations
  • addressed affiliated transaction issues under the Investment Company Act
  • advised on board reporting issues


  • Presenter, “What You Need to Know About Money Market Fund Reform,” Philadelphia Bar Association Investment Companies Committee
  • Presenter, “Money Market Fund Reform: What the Board Needs to Know,” Mutual Fund Directors Forum
  • Presenter, “Money Market Funds: Status and Reform,” Securities Industry and Financial Markets Association (SIFMA)

Operations Conference

  • Presenter, Money Market Funds Asset Management Forum, SIFMA
  • Presenter, “Money Fund Regulation: 2a-7 Basics and History,” Crane Data Money Fund University
  • Presenter, “Money Market Funds: The Shifting Regulatory Landscape,” SIFMA Operations Conference
  • Presenter, “Money Market Fund Regulation: 2a-7 Basics and History” and “Regulatory Changes,” Crane Data Money Fund University
  • Presenter, “Money Fund Regulations: 2a-7 Basics and History,” and “Regulations II: Interpretations & Recent Changes,” Crane Data Money Fund University
  • Presenter, “Where are we Now and What’s Next?” Crane Data Money Fund Symposium
  • Presenter, “Money Market Funds: What’s Next under Dodd-Frank and other Regulatory Developments,” U.S. Bancorp Fund Services

Client Conference

  • Presenter, “Money Market Funds: Where We are Now and What’s Next?,” Investment Company Institute General Membership Meeting
  • Presenter, “Dodd-Frank and Money Market Funds: Caught in the Crossfire?,” Stradley Ronon
  • Presenter, “Amendments to Rule 2a-7: New Requirements for Money Market Funds and their Boards,” Mutual Fund Directors Forum

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