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O'Riordan, C. Dabney

C. Dabney O'Riordan

Partner

dabneyoriordan@quinnemanuel.com
Direct Tel: +1 202 538 8269
Los Angeles
Tel: +1 213 443 3000 Fax: +1 213 443 3100
Washington, D.C.
Tel: +1 202 538 8000 Fax: +1 202 538 8100

Dabney O’Riordan is a partner in Quinn Emanuel’s SEC Enforcement practice where she primarily focuses on advising private investment firms regarding SEC compliance and securities-related government inquiries and litigation, particularly for private investment firms.  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. 

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, spanning three presidential administrations, Dabney supervised hundreds of investigations across all the SEC’s offices, 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 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 andthe Marketing Rule. 

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.

  • University of California, Los Angeles School of Law
    (J.D., Order of the Coif, 1999)
         
  • Wellesley College
    (B.A. magna cum laude, Environmental Science, 1995)
  • The State Bar of California
  • District of Columbia Bar
  • U.S. Securities and Exchange Commission:
    • Chief/Co-Chief, Asset Management Unit, Division of Enforcement, 2016-2022
    • Associate Regional Director, Division of Enforcement, 2016
    • Assistant Director, Division of Enforcement 2012-2016
    • Counsel to the Director, Division of Enforcement, 2012
    • Senior Counsel, Division of Enforcement, 2005-2012
  • Munger, Tolles & Olson LLP:
    • Associate, 2000-2005
  • Law Clerk for the Honorable David R. Thompson:
    •  U.S. Court of Appeals for the Ninth Circuit, 1999-2000

Presentations

  • inSecurities "Compliance and Enforcement Considerations for Private Funds & RIAs" - Ep 90 PLI 
  • "Law, Disrupted: How Asset Managers can Minimize Risk with the SEC with C. Dabney O'Riordan" - Law Disrupted
  • May 2023 - "How an Investment Adviser Can Take Steps to Avoid a Costly SEC Enforcement Action: What to do if you discover a potential violation of the federal securities laws." - Firm Memoranda
  • March 2022 MFA West 2022 - “What’s Next on the Regulatory and Enforcement Agenda” - Managed Funds Association
  • March 2022 Investment Management Conference - “Good Cop, Bad Cop: Examinations and Enforcement Under the Gensler Commission” - Investment Company Institute
  • 2022 Compliance Conference - “Exams & Enforcement: A Conversation with Senior SEC Officials” - Investment Adviser Association
  • December 2021 GAIM Ops West - “SEC 2021 - Examining the latest priorities and exam questions” - GAIM Ops
  • November 2021 Life Insurance Company Products 2021 - “Recent SEC and FINRA Enforcement Developments” - ALI CEI
  • October 2021 -The SEC Speaks in 2021 - Division of Enforcement - Practicing Law Institute
  • September 2021 - ESG Considerations for Asset Managers - The Emerging Regulatory Framework Applying to Investment Funds and Investment Advisers 2021 - “The Evolving Regulatory Landscape” - Practicing Law Institute
  • July 2021 CCO Committee - Investment Company Institute
  • April 2021 MFA West 2021 - “What’s Next on the Regulatory and Enforcement Agenda” - Managed Funds Association
  • 2021 Legal and Regulatory Committee - Investment Adviser Association
  • 2021 Compliance Conference - “Conversations with the Division of Examinations Director and the Division of Enforcement’s Asset Management Unit Co-Chiefs - Investment Adviser Association
  • November 2020 Life Insurance Company Products - “SEC and FINRA Enforcement: Key Take-Aways from Recent Enforcement Actions and Areas of Focus” - ALI CEI