Welcome to the Q3 edition of JW Michaels & Co.’s Legal & Compliance Newsletter. This month we highlight important regulatory updates affecting the compliance landscape, notable industry moves in the legal and compliance world, and exciting new career opportunities. Read on for the latest insights and opportunities in the U.S. legal and compliance sector.
Regulatory & Industry Updates
- Private Funds Enhanced Disclosure Rule: Deadline Extended The SEC and CFTC extended the compliance deadline for private funds to begin reporting enhanced Form PF data on risk exposures—including investments, counterparties, currencies, industries, and countries—to October 1, 2026. Implication for managers: Use the additional time to build or refine data infrastructure, internal reporting processes, and governance controls so disclosures are accurate and defensible when the deadline arrives.[1]
- SEC Enforcement of Marketing Rule: The Securities and Exchange Commission demonstrated its tough stance on compliance by fining a Massachusetts investment adviser $75,000 for violating the SEC’s Marketing Rule and related recordkeeping requirements. The firm had made unsubstantiated “conflict-free” claims in its advertising and failed to retain required records, prompting the SEC action. This first enforcement under the new Marketing Rule highlights the need for firms to ensure truthful marketing and rigorous recordkeeping.[2]
- SEC–CFTC Regulatory Harmonization Effort: The SEC and CFTC announced a joint initiative to harmonize regulation across product definitions, reporting standards, exemptions, and capital/margin requirements. A public roundtable will be held later this year. Implication for managers: Multi-strategy funds trading derivatives, structured products, or operating across jurisdictions should prepare for potential adjustments to compliance frameworks. While harmonization may reduce duplicative reporting, it could also necessitate changes to existing compliance policies.[3]
- Executive Order on Alternative Assets in Retirement Plans: A White House executive order directs regulators to explore allowing greater access to alternative assets—including private equity, private credit, and infrastructure—within defined contribution plans like 401(k)s. Implication for managers: This could unlock significant new investor demand while simultaneously increasing scrutiny on product design, liquidity risk disclosures, and fee transparency. Alternative managers should be prepared for both growth opportunities and regulatory attention.[4]
[1] https://www.sec.gov/news/press-release/2023-141
[2] https://www.sec.gov/news/press-release/2023-118
[3] https://www.sec.gov/news/press-release/2019-93
[4] https://www.whitehouse.gov/briefing-room/statements-releases/2025/08/07/fact-sheet-executive-order-on-retirement-security/
Key Hires & Industry Moves
- Oran Ebel has joined Davis Polk as a Partner after 12 years at Blackstone Credit & Insurance, where he was Managing Director and Deputy General Counsel as well as Chief Legal Officer & Secretary for BCRED and BXSL. At Blackstone, he developed deep expertise in structuring, forming, and operating both 1940 Act and private funds, with a particular focus on private credit platforms. Oran brings extensive experience in co-investment orders, complex affiliation considerations, and advising on product development across direct lending, asset-backed credit, mezzanine, insurance, and hybrid capital strategies—offering clients commercially focused guidance at the intersection of private credit, regulation, and fund innovation.
- Ariel Hazzard has joined GoldenTree Asset Management as an Executive Director to lead the firm’s ’40 Act alternative business lines. She was previously Chief Compliance Officer for Business Development Companies and Alternative Closed-End Funds at BlackRock, where she oversaw compliance and regulatory matters across a broad range of registered alternative products. Ariel brings significant expertise in navigating the complex governance, operational, and regulatory requirements of ’40 Act vehicles, and her move underscores GoldenTree’s commitment to expanding and institutionalizing its alternative registered fund offerings.
- Gladys Xiques has joined Thornburg Investment Management as Global Chief Compliance Officer, where she will oversee the firm’s global regulatory and asset management compliance program across ETFs, mutual fund complexes, and other investment products. She was previously Group Managing Director and Global CCO at TCW, where she spent more than a decade leading compliance strategy and governance initiatives across the firm’s global platform. Gladys brings deep experience in managing complex regulatory frameworks for large-scale asset managers, and her move reflects Thornburg’s focus on strengthening its global compliance and risk infrastructure.
- Kyle DiGangi has joined Lazard Asset Management as Global Chief Compliance Officer, where he will lead the firm’s compliance program across its $240B+ AUM global platform. He was previously Senior Vice President, Global Head of Compliance & Associate General Counsel at Alliance Bernstein, where he spent nearly seven years overseeing compliance strategy and regulatory matters across multiple business lines. Kyle brings significant expertise in navigating global regulatory regimes and managing large-scale compliance functions, and his move underscores Lazard’s commitment to maintaining robust compliance standards as it continues to expand its global presence.
- Robert Marks has joined First Eagle Alternative Credit as Chief Compliance Officer, where he will oversee compliance across the firm’s private credit business lines, including CLOs, CDOs, SMAs, and BDCs. He was previously a Senior Compliance Officer at Golub Capital, where he supported the firm’s credit strategies and regulatory framework. Robert brings strong expertise in private credit compliance and governance, and his move highlights First Eagle’s commitment to strengthening oversight and risk management as it continues to scale its alternatives platform.
- Sumana Setty has joined Blue Owl as Managing Partner and General Counsel of its Private Equity and GP Stakes business. She will oversee legal strategy, governance, and regulatory matters across the platform as Blue Owl continues to scale its alternatives footprint. Sumana was previously General Counsel and Managing Director at Wafra, where she spent the past three years leading legal, compliance, and strategic initiatives. Earlier in her career, she was a Partner at Kirkland & Ellis, where she gained extensive training in private equity and fund formation. Her move to Blue Owl underscores the firm’s focus on strengthening its leadership bench and legal capabilities to support the growth of its private equity and GP stakes strategies.
- Anna Spector has joined Lane42 Investment Partners as Partner and Chief Compliance Officer. She was previously Global Chief Compliance Officer, Managing Director, and Head of ESG at CVC Credit, where she spent eight years leading global compliance and sustainability initiatives. Lane42, founded by Scott L. Graves and seeded with a $2 billion capital commitment from Millennium affiliates, is an alternative asset manager focused on capturing inefficiencies across public and private markets and the convergence of debt and equity financing.
(These industry moves indicate a vibrant market for seasoned legal and compliance professionals, as companies across sectors invest in leadership to manage risk and regulation.)
Featured Open Positions & Opportunities
JW Michaels & Co. is actively recruiting for several exciting legal and compliance roles. Below are a few featured openings across the U.S. – if you or someone in your network is interested, our team would be happy to discuss these opportunities:
- VP, Compliance Officer – Investment Management (CT): Our client, a top investment firm in the New York/Connecticut area, seeks a Vice President, Compliance Officer with 5+ years’ experience. This generalist compliance role involves overseeing Code of Ethics compliance, personal trading oversight, regulatory filings, employee training, and policy development. It’s a great opportunity for a mid-level compliance professional to step up and shape a firm’s compliance program.
- Head of Funds Counsel – Multi-Strategy Alternative Asset Manager (NYC): Seeking a Head of Funds Counsel to oversee fund structuring, LP negotiations, fund launches, and regulatory compliance across private equity and credit vehicles. Requires 10–15 years at a top law firm and/or fund with deep fund formation experience.
- Corporate Counsel, M&A – Alternative Investment Firm (NYC): Hiring a Corporate Counsel (M&A) to support platform acquisitions, bolt-ons, and portfolio governance. Requires strong big-law M&A training and ~5–7 years of experience.
- Commercial Director / Counsel, M&A & PE – Global Infrastructure Fund (NYC): A global infrastructure-focused investment firm seeks a Commercial Director/Counsel to advise on strategic M&A, PE investments, and portfolio company matters. Requires 8–12 years’ transactional experience and strong commercial acumen.
- Associate Counsel, M&A & PE – Multi-Family Office Investment Platform (NYC):
Seeking an Associate Counsel to support deal execution, portfolio company matters, and general corporate work. Ideal for big-law associates (3–6 years) seeking an in-house transition.
- Senior Compliance Officer – Private Equity Firm (Miami or NYC): Looking for a Senior Compliance Officer to oversee personal trading, marketing reviews, and SEC compliance initiatives. Requires 6+ years of private fund compliance experience.
- Deputy General Counsel – Investment Management (Remote with Travel):
Our client, a leading global investment manager, is seeking a Deputy General Counsel with 10–15 years of experience at a top law firm and/or in-house. The ideal candidate will bring strong 40 Act expertise with a focus on registered funds, including public funds such as BDCs, as well as international fund experience (e.g., Luxembourg structures). This role requires a commercially minded attorney with excellent interpersonal skills who can effectively partner with senior leadership. The position can be fully remote with periodic travel, and candidates may be based in major U.S. markets across Eastern, Central, or Mountain time zones.
Thank you for reading the JW Michaels October Newsletter. We strive to keep you informed and engaged with the latest developments in the legal and compliance field. If you have any questions or would like to discuss your hiring needs or career goals, please contact us. Stay tuned for next month’s update and have a great October.
