Practices

Paul M. Miller is a partner in Seward & Kissel’s Investment Management Group and is located in Seward & Kissel’s Washington D.C. office. Paul joined Seward & Kissel in 1998 and became a partner in 2008.

Paul’s practice focuses primarily on registered investment companies and registered investment advisers.  He has worked extensively on matters affecting registered funds and ETFs, including their formation, their registration with the Securities and Exchange Commission (SEC) under the Investment Company Act of 1940, their service provider arrangements with investment advisers, distributors, transfer agents and custodians and their ongoing regulatory reporting and compliance obligations. He has also worked on the full range of matters affecting registered investment advisers, including their formation, their registration with the SEC under the Investment Advisers Act of 1940, their participation in managed account and wrap programs and their ongoing regulatory reporting and compliance obligations. He regularly advises registered funds, ETFs, and registered advisers on matters relating to their periodic examination by the staff of the SEC. He has advised the independent directors/trustees of mutual funds concerning their responsibilities under the Investment Company Act of 1940 and state law.

Paul has authored or co-authored several articles, including, “Privacy and Cybersecurity: How Advisers Must Protect their Clients’ Most Valuable Asset,” Investment Adviser Association Newsletter, August 2022; “Use of Alternative Data by Investment Advisers,” Investment Adviser Association Newsletter, August 2021; “Can the Tax Efficiencies of ETF Redemptions In-Kind Be Replicated for Mutual Funds?” The Investment Lawyer, February 2020; “What’s in a Name? ETF or Not – Does it Matter?” Investment Adviser Association Newsletter, May 2018; The Hot Money: Cryptocurrencies and Implications for Investment Advisers,” Investment Adviser Association Newsletter, November 2017, “Revisiting Annual Compliance Reviews,” Investment Adviser Association Newsletter, October 2015; “Asset Managers Now Obliged to Supply More Data to the SEC,” COO Connect, June 2015; “Proxy Voting by Investment Advisers: One Sentence and Eleven + Years of Experience,” Investment Adviser Association Newsletter, November 2014; “Soft Dollars Revisited,” Investment Adviser Association Newsletter, June 2013; “The JOBS Act: Implications for Private Fund Advertising and for Compliance Programs of Registered Advisers to Private Funds,” Investment Adviser Association Newsletter, May 2012; “Large Traders: A Review of Rule 13h-1 and Form 13H,” Investment Adviser Association Newsletter, December 2011; “Insider Trading and Corresponding Compliance Policies and Procedures of Investment Advisers,” Investment Adviser Association Newsletter, March 2010; “Compliance Monitoring and Testing,” Investment Adviser Association Newsletter, February 2008; and “Complying with State Gaming Regulations,” Investment Adviser Association Newsletter, March 2006.

Paul is a member of the Federal Bar Association and the Virginia Bar Association.

Publications