Michael Berenson

Senior Counsel

Michael Berenson concentrates on securities law matters involving investment products issued by insurance companies, including variable annuities and variable life insurance. He is nationally recognized in the field of variable products. Michael advises on private placements of variable products and their underlying investment options, including hedge funds. Michael also has significant experience with exchange traded funds.

Extended Profile

Prior to private practice, Michael was chief of the Division of Investment Management’s Office of Insurance Products and Legal Compliance at the US Securities and Exchange Commission (SEC), where he supervised the processing of all insurance company SEC registered products. He also directed the development of the SEC’s Rule 6e-3(T) under the Investment Company Act of 1940, dealing with variable life insurance, and Rule 151 under the Securities Act of 1933, dealing with the status of annuity contracts under the federal securities law. Past positions at the SEC include chief of the Division’s Investment Advisers Study Group and Special Counsel in Charge of Compliance. At the SEC, Michael dealt with issues arising under the Investment Company Act and the Investment Advisers Act relating to financial services offered through broker-dealers, banks, insurance companies, and investment bankers.

Michael frequently participates on securities law panels at the ALI/ABA Conference on Securities and Tax Aspects of Life Insurance Company Products, the Investment Company Institute Procedures Conference, and the Mutual Funds Conference, among others.