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Contact details

Allen & Overy LLP
1101 New York Avenue, NW
Washington, DC
United States

Telephone icon+1 202 683 3882
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  Marc Ponchione


Washington, D.C.

Marc’s practice focuses on the asset management industry where he advises clients on a broad spectrum of regulatory and transactional issues. Marc is fluent in all aspects of regulation affecting money managers, funds and fund sponsors and he focuses particularly on issues under the Investment Company Act of 1940 and the Investment Advisers Act of 1940. Marc regularly advises asset managers, sponsors and issuers in structuring, documenting and offering funds and other investment products inside and outside the U.S., including funds registered under the 1940 Act, private funds, specialty finance products such as securitization vehicles, CLOs, REITs and other real estate vehicles (including equity crowdfunding for real estate sponsors), and advises asset managers on regulatory and transactional issues under the Investment Advisers Act, including registration with the Securities and Exchange Commission and exemptions from registration. Marc also has considerable capital markets experience, having represented issuers and underwriters in creating and structuring hundreds of products and transactions to avoid 1940 Act “status” issues.

Prior to joining Allen & Overy, Marc worked in the asset management group of Willkie Farr & Gallagher from 2006-2012, and was senior counsel at the Securities and Exchange Commission (Division of Investment Management) from 2001-2006.

Professional qualifications

Admitted: Bar of District of Columbia, 2006 

Admitted: Bar of the Commonwealth of Pennsylvania, 1999

Academic qualifications

B.A., Marietta College, 1996

J.D., Duquesne University, 1999

Published work

"1940 Act Issues in Fund Finance Transactions," Fund Finance 2017, Global Legal Insights (2017)

"US Mutual Fund Swing Pricing Proposal:  What Can We Learn from Europe?," The Investment Lawyer (Jan. 2016), with David Solander, Yannick Arbaut, and Renaud Graas

"1940 Act Funds: Commercial and Operational Issues for Non-U.S. and U.S. Alternative Managers," Allen & Overy ePublication (Jan. 2016) 

"Non-US Banks May Invest in Third-Party Covered Funds Under the SOTUS Exemption," The Investment Lawyer (June 2015), with David Solander

"Non-U.S. Investment Funds and Managers: Regulatory Framework for Raising Capital in the U.S.," Allen & Overy ePublication (June 2015) 

"Private Equity Funds and the Volcker Rule," 47 Rev. Sec. & Commodities Reg. 171 (July 2014) (co-author)

"The Volcker Rule’s Relevance for Asset Managers," The Investment Lawyer (May 2014)

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