Mr. Ji has significant experience in advising investment management firms in registering with, and operating as, investment advisers with the SEC. He counsels clients on the application of the Advisers Act Section 206 fiduciary duty and disclosure obligations, portfolio management, custody rule, and marketing rule, as well as the implementation of compliance programs as required by Rule 206(4)-7 under the Advisers Act. Additionally, he has experience dealing with “status” issues arising under the Advisers Act and the Investment Company Act of 1940. Mr. Ji also provides regulatory advice in connection with internal compliance reviews, examinations and investigations by the SEC, and the development and review of compliance programs.
Prior to joining Goodwin, Mr. Ji was Senior Counsel at the Division of Examinations of the U.S. Securities and Exchange Commission. There, he led SEC examinations of domestic and foreign registered investment advisers. As examinations team lead, he evaluated investment advisers, principally with regards to compliance with the Advisers Act, including registration statements and regulatory filings with the Commission, portfolio management processes and disclosures, custody, marketing and advertising materials, fees and expenses, and compliance policies and procedures. In cases where an examination escalated into an enforcement matter, Mr. Ji served as liaison between the Division of Examinations and the Division of Enforcement.