Investment Management History For over 85 years, Stradley Ronon’s investment management n 1995-1998 practice has helped shape the mutual fund industry by assisting We structure and establish a unique product for a major with the creation of innovative investment products and fund complex, which leads to the establishment of an services. From obtaining “industry first” exemptive and institutional fund organization that could invest a portion of no-action relief to assisting in the development of novel its assets in other affiliated funds for asset allocation products, we have helped our clients become or remain purposes and not as a traditional fund-of-funds. The fund industry leaders. organization is established as a 1940 Act-only registered vehicle. OUR History Stradley Ronon has been representing registered investment companies and assisting clients with new and innovative investment products for over 85 years. Stradley Ronon has been representing investment companies and assisting clients with n 1928 new and innovative investment products for Stradley Ronon partner Andrew Young helps establish the over 85 years. Wellington Fund, one of the first mutual funds in the United States. Today, the Wellington Fund is a member of the Vanguard family of funds and continues to be managed by Wellington Management Company. n 1997 Stradley Ronon drafts and establishes one of the first n 1935 unregistered money-market sweep vehicles in the country. Mr. Young forms the investment firm that ultimately becomes Delaware Management Company. He also forms n 2003-2005 that firm’s flagship fund, the Delaware Fund. Stradley Ronon We establish certain fund structures that are used for continues to represent both DMC and the Delaware investment by wrap-fee products, which are modeled after Fund today. the one originally established for PIMCO, known as the “FISH” product. n 1940 The Investment Company Act of 1940 is enacted into law. n 2009 Mr. Young attends the congressional hearings leading up to Our attorneys secure a no-action letter from the SEC, giving its enactment. a major mutual fund complex permission to participate in the Term Asset-Backed Securities Loan Facility (TALF). This n 1960-1975 letter has served as the principal guidance for the industry Stradley Ronon creates one of the first fund-of-funds with respect to the TALF. structures in the industry. Our firm drafts and negotiates with the SEC the exemptive application that leads to the n 2012 creation of The Vanguard Group, Inc., which remains one of On behalf of a client, we obtain the first manager-of- the most unique and innovative structures in the mutual managers exemptive order that covers both affiliated and fund industry. unaffiliated sub-advisers since the SEC stopped issuing such orders in the 1990s. n 1980-1994 Prior to the adoption of Rule 18f-3, Stradley Ronon drafts one of the very first multiple classes’ exemptive applications. We establish master/feeder structures, which involve both the conversion of funds to such structures and (continued) the establishment of such structures anew. PENNSYLVANIA | WASHINGTON, D.C. | NEW YORK | NEW JERSEY | DELAWARE Investment Management History n Present Today we are assisting clients in ushering in the latest iteration of registered investment company products that Stradley Ronon Stevens & Young, LLP offer “alternative” investment strategies. Bringing together www.stradley.com our knowledge with regulatory funds that have exposure to Bruce G. Leto commodities, real estate and complex derivatives, our Chair, Investment Management attorneys are assisting funds and their sponsors navigate 215.564.8115 | [email protected] evolving SEC, CFTC and NFA regulations, swaps and other Matthew R. DiClemente derivatives trading regulations, and other regulations Partner, Investment Management impacting alternative investment strategies both in the 215.564.8173| [email protected] United States and abroad. PENNSYLVANIA | WASHINGTON, D.C. | NEW YORK | NEW JERSEY | DELAWARE.