Thomas Bisset, a member of Sutherland’s Financial Services Practice Group, counsels financial institutions, in particular investment companies, insurance companies and banks on a wide variety of corporate and securities law matters. His practice focuses on investment management, including investment company, investment adviser and variable insurance product regulatory matters.
Previously, Thomas served as a Senior Counsel in the Office of Insurance Products in the U.S. Securities and Exchange Commission’s (SEC) Division of Investment Management, where he worked on a wide variety of Division activities including disclosure review, exemptive applications and no-action letters, rulemaking and investment company examinations. He also served for two years as a staff attorney in the SEC’s Division of Market Regulation. During his tenure with the SEC, Thomas participated in several significant SEC projects, including the October 1987 Market Break Study. He has extensive experience in all aspects of the SEC’s inspections and examination programs.
REPRESENTATIVE EXPERIENCE
Thomas’ extensive representative experience includes:
Investment Management
- Counseling clients in connection with various types of mutual funds including funds-of-funds, sub-advised funds, lifestyle and target-date funds, and insurance products funds.
- Serving as independent counsel to independent mutual fund trustees.
- Developing compliance policies and procedures and compliance systems for mutual funds.
Insurance
- Counseling clients in the design of a wide variety of cutting-edge equity indexed annuity, variable annuity and variable life insurance products.
- Counseling clients in connection with a number of M&A transactions involving life insurance companies and their separate accounts.
- Counseling clients in connection with the distribution of insurance products.
RECENT PUBLICATIONS AND SPEAKING ENGAGEMENTS
- Co-author, "Soft Dollars, Investment Adviser Regulation - A Step by Step Guide to Compliance and the Law," Practising Law Institute, Third Edition, Volume 1, Chapter 17 (2011)
- Co-author, “SEC Adopts New Soft Dollar Guidelines,” The Investment Lawyer (September 2006)
- Co-author, “SEC Clarifies Meaning of Research and Brokerage in Proposed Soft Dollars Release,” The Investment Lawyer (January 2006)
- Co-author, “Privately Place VLI Products: Charting The Regulatory Waters,” ALI-ABA Conference on Life Insurance Company Products: Current Securities, Tax, ERISA, and State Regulatory Issues (September 2000)
- Co-author, “Roundtable on the Role of Independent Investment Company Directors: Issues for Independent Directors of Bank-Related Funds, Variable Insurance Product Funds, and Closed-End Funds,” The Business Lawyer, Volume 55, Number 1 (November 1999)
- Co-author, “Legal, Regulatory, and Accounting Issues,” The Handbook of Stable Value Investments (1998)
- Speaker, “Fundamental of Mutual Funds and Exchange - Traded Funds 2011,” Practising Law Institute (June 8, 2011)
- Speaker, “Commission Sharing vs. Traditional Soft Dollar Agreements,” 2010 NSCP National Meeting (November 2, 2010)
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