David A. Sturms
Shareholder
T: +1 (312) 609 7589
F: +1 (312) 609 5005
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Chicago
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E:
Chair, Investment Services Group
David A. Sturms is a Shareholder and Chair of Vedder Price's Investment Services group. Prior to joining Vedder Price in 1994, Mr. Sturms was a principal of an investment management firm, Stein Roe & Farnham. Mr. Sturms has practiced corporate and securities law since 1985, concentrating in investment company matters. He has extensive experience in advising investment companies and investment advisers on all aspects of the Investment Company Act of 1940 and the Investment Advisers Act of 1940, and in counseling independent directors of investment companies on their duties and responsibilities under the law. Mr. Sturms was a participant in the SEC Roundtable on the Role of Independent Investment Company Directors and consulted with the ICI Advisory Group on Best Practices for Fund Directors. His publications include "Enhancing the Effectiveness of Independent Directors: Is the System Broken, Creaking or Working?," Villanova Journal of Law and Investment Management (Fall 1999). Mr. Sturms also served on the American Bar Association Task Force that drafted the Fund Director’s Guidebook (2003 and 2006).
Mr. Sturms was selected for inclusion from 2008 to 2012 in Illinois Super Lawyers. He has received an "AV Preeminent" Peer Rating in Martindale-Hubbell from 2001 to 2011. In addition, the Legal 500 United States recommends Mr. Sturms as a "bona fide '40 Act specialist" who brings "preparation, experience and good counsel time and again."
Mr. Sturms served on the Investment Company Institute’s SEC Rules and State Committees, as well as the money market funds, advertising, compliance, creditors’ rights and various other ad hoc committees.
Mr. Sturms currently is a member of the Chicago Bar Association’s Investment Company Subcommittee and the American Bar Association’s Subcommittee on Investment Companies and Investment Advisers. Mr. Sturms was appointed by the Illinois Secretary of State and served on the Illinois Securities Advisory Committee.
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Mr. Sturms is a frequent speaker and author on investment management issues, including:
mergers and acquisitions of investment companies and investment advisers
federal and state registration of investment companies and investment advisers
investment company independent directors
D&O/E&O insurance
closed-end funds
exchange-traded funds (ETFs)
valuation
audit committees
money market funds
compliance
derivative instruments
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- J.D., Loyola University of Chicago, 1985
- B.S., Ohio State University, 1982
- Illinois, 1985
- US Supreme Court, 2009
- Member, Investment Company Subcommittee, Chicago Bar Association
- Member, Subcommittee on Investment Companies and Investment Advisers, American Bar Association
Speaking Engagements and Publications
- “Mutual Fund D&O/E&O Insurance; An Overview for Independent Directors”; Independent Directors Council (June 17, 2009)
- “Board Responses to a Shifting Financial Landscape; Recent Market Events: Strategic Considerations”; 2009 Investment Company Directors Workshop, Independent Directors Council (April 17, 2009)
- “Risk Management Seminar for Investment Advisers and Mutual Funds” (February 26, 2009)
- Chapter 6, “Regulation of the Advisory Contract,” and Chapter 7, “Regulation of Advisory Fees,” in Mutual Fund Regulation , edited by Clifford E. Kirsch (2003, 2006 and 2009)
- American Bar Association Task Force, Fund Director’s Guidebook (2003 and 2006) (co-authored)
- “The Basics of Indemnification and Insurance for Investment Company Directors — How do they work? What should I ask?,” 2003 Investment Company Institute Investment Company Directors’ Conference (October 16, 2003)
- “Valuation Issues for Mutual Fund Directors,” 2001 Investment Company Institute Investment Company Directors Conference (October/November 2001)
- “Fair Value Pricing,” The Directors Roundtable (June 7, 2001)
- “Mutual Fund Corporate Governance and Other ‘Breaking’ SEC Initiatives,” The Directors Roundtable (February 8, 2001)
- “Fund Governance and Board Reporting (Independence: Is it a State of Mind or can it be Regulated?),” 2000 Investment Company Institute Tax and Accounting Conference (September 2000)
- “Investment Advice: What Will the Future Hold?,” 2000 Investment Company Institute General Membership Meeting (May 2000)
- “Enhancing the Effectiveness of Independent Directors: Is the System Broken, Creaking or Working?,” Villanova Journal of Law and Investment Management (Fall 1999)
- “What Directors Should Know About Indemnification and Insurance,” 1999 Investment Company Institute Investment Company Directors Conference (October/November 1999)
- “Legal Liabilities Arising from the Mutual Fund Disclosure Initiatives (Form N-1A Amendments, ‘Profile,’ ‘Plain English’), Glasser LegalWorks Third Annual Institute on Investment Management Regulation (October 12, 1999)
- “The Best Execution Quagmire: Solutions for Successful Navigation,” NICSA (September 9, 1999)
- “New Services, New Problems: Helping CPAs Through the Regulatory Maze,” Investment Adviser Regulations (July 22, 1999)
- Statement before the Investment Company Institute Advisory Group on Best Practices for Fund Directors (April 26, 1999)
- “Enhancing the Effectiveness of Independent Directors to Perform Their Duties under the Investment Company Act of 1940 — The Debate: The System Is Broken — Fix It or Scrap It vs. the System Works — Don’t Fix What Isn’t Broken,” SEC Roundtable on the Role of Independent Investment Company Directors (February 1999)
- “Form N-1A Liability Issues — ‘It’s Déjá Vu All Over Again,’” Investment Company Institute Disclosure Reform Conference (April 23, 1998)
- “Investment Advisers Supervision Coordination Act, Regulation Issues Posed by Mutual Fund Asset Allocation Programs and Trade Allocation Procedures,” Schwab Institutional Investment Manager Forum (July 24, 1997)
- “Investment Adviser Trading Issues,” 1999 NSCP National Membership Meeting (October 24, 1996)
- Board Presentations, Investment Company Institute 1996 Tax and Accounting Conference (September 1996)
- “Board of Directors Compliance Issues under Rule 2a-7,” Investment Company Institute Conference on Money Market Fund Regulation (May 10, 1996)
- “Asset Allocation Products,” Moderator, 1996 Mutual Funds and Investment Management Conference (March 1996)
- “Regulatory Issues Posed by Mutual Fund Asset Allocation Programs,” Investment Manager Forum (February 29, 1996)
- “Money Market Funds Selected Issues (The ‘Approximates Par’ Requirement, Mandatory Tenders and Adviser Bailouts)”, 1996 Mutual Funds and Investment Management Conference (February 1, 1996)
- “Trade Allocation Procedures: An Update on ‘Bunching,’” NSCP Currents (November/December 1995) (with Robert J. Moran)
- “Investment Adviser Registration and Regulation,” 1995 AICPA Investment Planning Conference (June 13, 1995)
- “Why and How to Design and Implement Trade Allocation Procedures,” NSCP Currents (May/June 1995) (with Robert J. Moran)
- “Dealing with Derivatives,” 1994 Investment Company Institute Tax and Accounting Conference (September 27, 1994)
- “State Developments,” Moderator, 1994 Mutual Funds and Investment Management Conference (March 1994)
- Panel on Derivative Investments, 1993 ICI Securities Law Procedures Conference (December 2, 1993)
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