Biography
Paul’s practice focuses primarily on registered investment companies and registered investment advisers.
Paul advises registered funds, including mutual funds, ETFs and interval/tender offer funds, concerning 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 represents the independent directors/trustees of registered funds and advises them on their responsibilities under the Investment Company Act of 1940 and state law.
Paul counsels registered investment advisers (RIAs) regarding 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.
Paul represents these registered funds and RIA clients on matters relating to their periodic examination by the SEC staff, submissions (exemptive applications and no-action letter requests) to the SEC and its staff and responding to other regulatory inquiries and comments.
Capabilities
Areas of Focus
Credentials
Education
Syracuse University College of Law
- J.D., 1998
- cum laude
University of North Carolina at Chapel Hill, Kenan – Flagler Business School
- B.A, 1994
Bar Admissions
- District of Columbia
- Virginia [Member of Virginia Bar Association]
Representative Work
- ETF Share Class Order: Advised AB Funds in connection with the preparation and filing of an application, on behalf of AllianceBernstein L.P. (and AB Municipal Income Fund, Inc. (the “Company”), a Maryland Corporation, for an order of the Securities and Exchange Commission for an exemption from Sections 2(a)(32), 5(a)(1), 18(f)(1), 18(i), 22(d) and 22(e) of the 1940 Act and Rule 22c-1 under the 1940 Act and under Sections 6(c) and 17(b) of the 1940 Act for an exemption from Sections 17(a)(1) and 17(a)(2) of the 1940 Act. The Order is intended to apply not only to existing and future series of the Company but also to other existing or future open-end management investment companies registered under the 1940 Act and series thereof (each a “Fund,” and together, the “Funds”) that are actively managed and advised by the Adviser. If granted exemptive relief, the Order would permit a Fund to offer a class of exchange-traded shares in addition to classes of shares that are not exchange-traded. This order was issued on January 13, 2026.
- Advised large registered fund complex in establishing a “unitary” board structure, including the preparation proxy materials for stockholder meetings approving the election of directors.
- Advised a registered investment adviser and a mutual fund that invested in Sears Holdings Corporation in connection with an adversary proceeding filed by the Restructuring Subcommittee of Sears Holdings Corporation against various shareholders, directors, and officers of Sears Holdings Corporation in which plaintiffs asserted claims for breach of fiduciary duty, aiding and abetting breach of fiduciary duty, and conveyance claims seeking to recover over $1.6 billion in damages and transfers arising out of Sears corporate transactions.
- ETF Conversion: Advised AB Active ETFs, Inc. and AB Bond Fund Inc. in connection with the conversion of AB Total Return Bond Fund, a series of AB Bond Fund, Inc., into AB Core Plus Bond ETF, a series of AB Active ETFs, Inc.
- Advised a registered investment company and its registered investment adviser in connection with obtaining an SEC exemptive order to permit the adviser, on behalf of a fund and subject to the approval of the board, to hire, and to modify any existing or future subadvisory agreement with, unaffiliated sub-advisers and affiliated sub-advisers (Manager-of-Managers Structure).
- Preferred stock offering: Advised a registered, exchange-traded closed-end fund in connection with the issuance and sale of Variable Rate Demand Preferred shares (VRDPs) pursuant to an offering exempt from registration under the Securities Act of 1933. The Fund used the proceeds of the issuance, in conjunction with proceeds from the creation of tender option bond trusts by the Fund, to simultaneously redeem certain outstanding Variable Rate MuniFund Term Preferred shares (VMTPs)
- January 2025: Advised Kinetics Funds (including Kinetics Mutual Funds, Inc., a series of eight mutual funds, and Kinetics Portfolios Trust) on statutory and regulatory matters relating to fund operation and compliance programs; counsel the board of directors on fund matters and participate in board meetings; and review and prepare materials in connection with regulatory filings.
Recognitions
- Recognized by Chambers USA: Registered Funds
- Recognized by Chambers Global
Publications
- “Privacy and Cybersecurity: How Advisers Must Protect their Clients’ Most Valuable Asset,” Investment Adviser Association Newsletter (2024)
- “Use of Alternative Data by Investment Advisers,” Investment Adviser Association Newsletter (2021)
- “Can the Tax Efficiencies of ETF Redemptions In-Kind Be Replicated for Mutual Funds?” The Investment Lawyer (2020)
- “What’s in a Name? ETF or Not – Does it Matter?” Investment Adviser Association Newsletter (2018)
- “The Hot Money: Cryptocurrencies and Implications for Investment Advisers,” Investment Adviser Association Newsletter (2017)
- “Revisiting Annual Compliance Reviews,” Investment Adviser Association Newsletter (2015)
- “Asset Managers Now Obliged to Supply More Data to the SEC,” COO Connect (2015)
- “Proxy Voting by Investment Advisers: One Sentence and Eleven + Years of Experience,” Investment Adviser Association Newsletter (2014)
- “Soft Dollars Revisited,” Investment Adviser Association Newsletter (2013)
- “The JOBS Act: Implications for Private Fund Advertising and for Compliance Programs of Registered Advisers to Private Funds,” Investment Adviser Association Newsletter (2012)
- “Large Traders: A Review of Rule 13h-1 and Form 13H,” Investment Adviser Association Newsletter (2011)
- “Insider Trading and Corresponding Compliance Policies and Procedures of Investment Advisers,” Investment Adviser Association Newsletter (2010)
- “Compliance Monitoring and Testing,” Investment Adviser Association Newsletter (2008)
- “Complying with State Gaming Regulations,” Investment Adviser Association Newsletter (2006)
Areas of Focus
Credentials
Education
Syracuse University College of Law
- J.D., 1998
- cum laude
University of North Carolina at Chapel Hill, Kenan – Flagler Business School
- B.A, 1994
Bar Admissions
- District of Columbia
- Virginia [Member of Virginia Bar Association]
Representative Work
- ETF Share Class Order: Advised AB Funds in connection with the preparation and filing of an application, on behalf of AllianceBernstein L.P. (and AB Municipal Income Fund, Inc. (the “Company”), a Maryland Corporation, for an order of the Securities and Exchange Commission for an exemption from Sections 2(a)(32), 5(a)(1), 18(f)(1), 18(i), 22(d) and 22(e) of the 1940 Act and Rule 22c-1 under the 1940 Act and under Sections 6(c) and 17(b) of the 1940 Act for an exemption from Sections 17(a)(1) and 17(a)(2) of the 1940 Act. The Order is intended to apply not only to existing and future series of the Company but also to other existing or future open-end management investment companies registered under the 1940 Act and series thereof (each a “Fund,” and together, the “Funds”) that are actively managed and advised by the Adviser. If granted exemptive relief, the Order would permit a Fund to offer a class of exchange-traded shares in addition to classes of shares that are not exchange-traded. This order was issued on January 13, 2026.
- Advised large registered fund complex in establishing a “unitary” board structure, including the preparation proxy materials for stockholder meetings approving the election of directors.
- Advised a registered investment adviser and a mutual fund that invested in Sears Holdings Corporation in connection with an adversary proceeding filed by the Restructuring Subcommittee of Sears Holdings Corporation against various shareholders, directors, and officers of Sears Holdings Corporation in which plaintiffs asserted claims for breach of fiduciary duty, aiding and abetting breach of fiduciary duty, and conveyance claims seeking to recover over $1.6 billion in damages and transfers arising out of Sears corporate transactions.
- ETF Conversion: Advised AB Active ETFs, Inc. and AB Bond Fund Inc. in connection with the conversion of AB Total Return Bond Fund, a series of AB Bond Fund, Inc., into AB Core Plus Bond ETF, a series of AB Active ETFs, Inc.
- Advised a registered investment company and its registered investment adviser in connection with obtaining an SEC exemptive order to permit the adviser, on behalf of a fund and subject to the approval of the board, to hire, and to modify any existing or future subadvisory agreement with, unaffiliated sub-advisers and affiliated sub-advisers (Manager-of-Managers Structure).
- Preferred stock offering: Advised a registered, exchange-traded closed-end fund in connection with the issuance and sale of Variable Rate Demand Preferred shares (VRDPs) pursuant to an offering exempt from registration under the Securities Act of 1933. The Fund used the proceeds of the issuance, in conjunction with proceeds from the creation of tender option bond trusts by the Fund, to simultaneously redeem certain outstanding Variable Rate MuniFund Term Preferred shares (VMTPs)
- January 2025: Advised Kinetics Funds (including Kinetics Mutual Funds, Inc., a series of eight mutual funds, and Kinetics Portfolios Trust) on statutory and regulatory matters relating to fund operation and compliance programs; counsel the board of directors on fund matters and participate in board meetings; and review and prepare materials in connection with regulatory filings.
Recognitions
- Recognized by Chambers USA: Registered Funds
- Recognized by Chambers Global
Publications
- “Privacy and Cybersecurity: How Advisers Must Protect their Clients’ Most Valuable Asset,” Investment Adviser Association Newsletter (2024)
- “Use of Alternative Data by Investment Advisers,” Investment Adviser Association Newsletter (2021)
- “Can the Tax Efficiencies of ETF Redemptions In-Kind Be Replicated for Mutual Funds?” The Investment Lawyer (2020)
- “What’s in a Name? ETF or Not – Does it Matter?” Investment Adviser Association Newsletter (2018)
- “The Hot Money: Cryptocurrencies and Implications for Investment Advisers,” Investment Adviser Association Newsletter (2017)
- “Revisiting Annual Compliance Reviews,” Investment Adviser Association Newsletter (2015)
- “Asset Managers Now Obliged to Supply More Data to the SEC,” COO Connect (2015)
- “Proxy Voting by Investment Advisers: One Sentence and Eleven + Years of Experience,” Investment Adviser Association Newsletter (2014)
- “Soft Dollars Revisited,” Investment Adviser Association Newsletter (2013)
- “The JOBS Act: Implications for Private Fund Advertising and for Compliance Programs of Registered Advisers to Private Funds,” Investment Adviser Association Newsletter (2012)
- “Large Traders: A Review of Rule 13h-1 and Form 13H,” Investment Adviser Association Newsletter (2011)
- “Insider Trading and Corresponding Compliance Policies and Procedures of Investment Advisers,” Investment Adviser Association Newsletter (2010)
- “Compliance Monitoring and Testing,” Investment Adviser Association Newsletter (2008)
- “Complying with State Gaming Regulations,” Investment Adviser Association Newsletter (2006)