Aline M. McCullough Associate

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Aline’s practice focuses on financial services regulatory matters that impact investment advisers, broker-dealers and funds.

Aline works with U.S. and non-U.S. investment managers, broker-dealers and funds on matters arising under the Investment Company Act, Advisers Act, CFTC regulations, and FINRA, SEC and NFA requirements affecting their businesses.

Aline advises investment advisers in the analysis of various Advisers Act questions, in drafting investment advisory agreements, preparation of marketing materials, compliance policies and procedures and Form ADV filings. She also works with investment managers and broker-dealers involved in regulatory investigations and securities enforcement matters including, the SEC, FINRA and state regulators.  In addition, Aline advises clients regarding their anti-money laundering compliance obligations.

Aline has advised clients on a wide variety of regulatory issues, including those relating to private equity transactions. She has also advised U.S. registered funds and their boards on a variety of compliance and disclosure matters and has extensive experience with investment company registration matters. She also has experience preparing materials for fund board meetings and attending board meetings.


  • Advised a dually-registered investment adviser and broker-dealer in regulatory investigations by the SEC, FINRA and state securities regulators relating to the institution’s supervisory obligations.
  • Counseled newly registered investment advisers on their adoption and implementation of compliance programs.
  • Advised investment advisers and broker-dealers on the regulatory implications of offering new products and funds.
  • Conducted internal investigations for investment adviser and broker-dealers.
  • Represented a dually-registered investment adviser in an enforcement matter regarding its books and records and production obligations.
  • Counseled investment advisers on updates to their compliance programs in response to the SEC’s amendments to the Marketing Rule.
  • Advised a foreign investment manager on its registration and compliance obligations with respect to SEC, CFTC and NFA requirements in connection with its U.S. activities.
  • Advised a broker-dealer on the design and implementation of a revised anti-money laundering compliance program.