Dabney O’Riordan is a partner in Quinn Emanuel’s SEC Enforcement practice where she primarily focuses on securities-related government inquiries and litigation, particularly for private investment firms and other asset managers. Dabney has extensive experience managing investigations and litigation, in particular matters involving the asset management industry, including advisers to private equity funds, hedge funds, venture capital funds, mutual funds, ETFs, business development companies, and separately managed accounts. In addition to representing clients in connection with SEC and other government matters, Dabney provides compliance counseling to asset managers.
A more than seventeen-year veteran of the SEC, Dabney was the longest-serving leader of the SEC Enforcement Division’s Asset Management Unit (AMU), which is a nationwide unit of approximately 60 lawyers and industry experts that leads the SEC’s efforts to investigate and litigate issues involving the asset management industry. During her more than six years leading the AMU, Dabney supervised hundreds of investigations, gaining extensive experience managing complex investigations and making ultimate investigative and litigation decisions, including the AMU’s investigative priorities, which cases to pursue, settlement terms to recommend to the SEC, and when and how best to litigate cases.
In leading the AMU, Dabney also directed the SEC Enforcement Division’s efforts to address emerging issues in the asset management industry. This work included participating on key task forces, providing guidance to other senior officers throughout the Enforcement Division, regularly collaborating with the Division of Examinations and Division of Investment Management, and engaging with the asset management industry. Among other things, Dabney was a member of the SEC Enforcement Division’s Climate and ESG Task Force and provided advice on the SEC’s 2019 Interpretation Regarding Standard of Conduct for Investment Advisers and various rules applicable to the asset management industry, including Regulation Best Interest, the Marketing Rule, the Proposed Private Fund Adviser Rule, and the Proposed ESG Disclosure Rule for Investment Advisers and Investment Companies.
Before leading the national AMU, Dabney led the SEC Los Angeles Regional Office’s Enforcement program as Associate Regional Director, overseeing the office’s enforcement priorities, investigations, and litigation involving public companies, insider trading, brokers, and investment advisers. Prior to that, Dabney spent eleven years investigating, litigating, and managing matters within the SEC’s Enforcement Division, working on novel and complex cases involving a wide range of issues falling within the SEC’s jurisdiction and frequently working in parallel with the federal criminal authorities.
Dabney’s extensive experience at the SEC has enabled her to develop creative, effective, and efficient solutions. For example, Dabney conceived of and led the SEC Enforcement Division’s Share Class Selection Disclosure Initiative. The initiative, which afforded advisers set settlement terms if they self-reported certain conduct to the Enforcement Division, resulted in settled resolutions with over 90 investment advisers in under nine months and was praised by then-Chairman Jay Clayton as having “immediate and lasting benefits . . .”
Prior to joining the SEC, Dabney was in private practice focusing on business litigation and served as a law clerk to the Honorable David R. Thompson of the Ninth Circuit Court to Appeals. She received her J.D. from UCLA School of Law, and a B.A. magna cum laude from Wellesley College.