MARTIN J.

ROSENBURGH, CFA, ESQ

Mobile: (646) 752-5253 • martinrosenburgh@gmail.com • Linkedin: https://www.linkedin.com/in/martin-j-rosenburgh-19978a5/

SUMMARY

Senior investment management attorney with background in global private debt/credit, finance and US retirement plans:

• Responsible for risk, due diligence, deal negotiation, structure and documentation at global private debt asset manager.
• 10+ years experience providing institutional investors and investment managers advice under US securities laws, laws
governing investment advisors and ERISA. Has provided representation to asset managers and banks in numerous
SEC/FINRA exams, inquiries and enforcement actions.
• 5+ years of experience as an ERISA/Employee Benefits attorney, advising large US retirement plans in plan fiduciary
requirements, investment arrangements and tax qualification issues.
• Small business advisory services, including independent valuation appraisals and compensation benchmarking analysis.
• 8+ years experience as equities trader, including successful completion of capital raising and investor due diligence process.

PROFESSIONAL EXPERIENCE

Cross Border Investment Management LLC, Washington D.C. Area February 2019 – Present
Chief Investment Officer and In-house Counsel
Responsible for legal risk, due diligence and transaction documentation and agreements at global private debt asset manager.
Senior member of investment team responsible for sourcing and managing portfolios of global private investments.
Strategies: Commercial Real Estate loans, Trade Finance, Asset-Backed Loans and European Government Receivable factoring.
Negotiate, draft and review terms under private offering and SPV documents, loan agreements, facilities and arrangements.
Represent firm in Noteholder and Creditor rights matters.
Developed and implemented firm processes for investment analysis, due diligence and risk management.
Sample of prior transactions:
• Investments in asset-backed Senior Notes collateralized by portfolios of commercial RE bridge loans in Spain and Germany.
• Investment in Euro Medium Term Notes financing a 100m EUR credit facility for an agro trader based in the Black Sea area.
• Due diligence for client-directed $60m debt investment in notes financing the acquisition of a Thermal power plant in India.
• 100m+ EUR investment in SPV-issued Senior Notes funding acquisition of Italian government funded healthcare receivables.
• Investment in SPV-issued Senior Notes funding acquisition of portfolio of Italian Non-Performing Loans.

Merrill Lynch, Bellevue, WA, November 2015 – December 2017

Business Manager - Team Financial Advisor Training Program
Served in business management and business development role in financial advisor team.
Provided retirement education and advice to executives regarding maximization of retirement and incentive plan benefits.
Managed team delivery of administrative services to participants in stock plan for company with $90 billion+ market cap.
Developed business in private wealth, corporate retirement and equity plan services market.

TriNet, San Leandro, CA September 2015 – November 2015

Interim ERISA/Employee Benefits Counsel
Served as ERISA counsel to Professional Employer Organization with $3 billion+ market capitalization.

Martin J. Rosenburgh, CFA, Esq, Mercer Island, WA March 2007 – September 2015
Attorney and Regulatory Compliance Consultant
SEC and ERISA Regulatory and Litigation Consulting (representative client list): Jackson Lewis LLP, Sullivan & Cromwell LLP and
Morvillo Abramowitz, Grand, Iason, Anello & Bohrer, P.C.
Advised clients and performed discovery analysis and document production in connection with securities and ERISA litigation
matters and SEC, FINRA and DOJ inquiries, examinations and investigations. Advised litigation defense teams regarding complex
financial issues, investment products and transactions, asset valuation methods and financial risk management practices.
• Assisted in criminal defense and forensic accounting reviews of financial reporting fraud actions in financial services industry.
• Conducted training seminars to brokerage compliance professionals regarding ERISA fiduciary and 408(b)(2) compliance issues.
• Served as expert witness in ERISA Taft-Hartley pension plan withdrawal liability arbitration regarding investment of plan assets.
• Advised a fiduciary trust company and sponsor of collective trust funds regarding fiduciary, operational and reporting issues
under ERISA and U.S. securities laws. Assisted in representing an ESOP trust company in DOL enforcement action.
• Advised litigation defense team in securities class action involving interest rate risk management practices at major retail bank.
• Investment manager compliance matters have included: use of material non-public information, front running, asymmetric
dissemination of client research, performance claims, marketing activities and client communications.
 Martin J. Rosenburgh, CFA, Esq Page 2

Investment Advisory and ERISA Compliance Consulting (client): RegEd, Morrisville, NC

Researched and developed investment advisory compliance software solution. Designed and drafted content regarding
compliance under the Investment Advisers Act of 1940, ERISA, the Investment Company Act of 1940 and securities laws.

Investment Advisory Compliance Consulting (client): Hudson Pilot LLC, New York, NY
Assisted in research and implementation of pension liability driven investing solutions and macroeconomic strategy. Researched
and drafted client communications regarding portfolio risk management, retirement plan design, funding and related corporate
finance, taxation, GAAP accounting and issues under ERISA.
• Assisted in developing firm compliance program and drafted written policies and procedures and Form ADV filings.
• Assisted in research and drafting of successful proposal to a $5 billion university endowment.
• Redesigned Investment Policy Statement for a $600 million pension plan.

Business Advisory Services (client): BMI (prior office of Marcum LLP), Los Angeles, CA
Performed independent business valuation analysis in connection with expert witness reporting and testimony.
• Developed and constructed valuation models using Asset, Income and Market approaches (industries of companies analyzed
include software services, hospitality, commercial real estate, agriculture and financial advisory services).
• Performed executive compensation benchmark analysis for pharmaceutical manufacturer with annual revenues of $80 Million.

ADDITIONAL PROFESSIONAL EXPERIENCE

Assent LLC (a division of SunGard), New York, NY 2001-2007

Senior Trader (with Lynx Capital Partners and Chimera Securities)
Developed and implemented mid and high frequency long/short equity proprietary trading strategies in NYSE listed securities.

Pryor Cashman Sherman & Flynn LLP, New York, NY 1996-2001

Proskauer Rose LLP, New York, NY
Grotta, Glassman & Hoffman, P.A., Roseland, NJ
Associate
Drafted, designed and implemented employee benefit plans, executive compensation programs, and investment-related
agreements and advised clients on related fiduciary legal and taxation issues. Advised clients regarding employee benefit plan
design, implementation and administration of qualified retirement plans and health and welfare plans. Researched and drafted
memoranda of law under the Internal Revenue Code and ERISA.
• Negotiated, designed and implemented plan investment-related arrangements, including trusts, investment consulting
agreements, investment management agreements and investment policy statements and advised clients on related issues.
• Performed benefits-related due diligence in mergers & acquisitions. Advised clients on taxation of equity-based compensation.
• Served as Taft-Hartley fund co-counsel. Advised fund clients regarding the selection and monitoring of investment managers.
• Developed 401(k) ADP and ACP nondiscrimination testing guidelines for plan administrators.

Lehman Brothers, New York, NY 1990-1993

Alex Brown & Sons, Inc., New York, NY
Retail Investment Representative
High net-worth client development and equity investment sales. Participated in underwriting syndicate sales.

EDUCATION

Brooklyn Law School, Brooklyn, NY J.D. Bar Admissions: New York 1996
Cornell University, Ithaca, NY B.A. Major: History 1989

PROFESSIONAL ACCOMPLISHMENTS

• Designations: CFA charter holder; passed Level 2 Exam of Certified Equity Professional certification
• Publications: “21st Century Pensions: the Risk, the Hedge and the Duty to Consider” (Hofstra Univ JIBL, 2009)
(co-authored) “TDFs: Ignorance Is Not Bliss” (Journal of NYSSA, The Investment Professional, Fall 2009)
(researched/edited): Michael Peskin, “Pension Funds and Corporate (Enterprise) Risk Management”, The Oxford Handbook of
Quantitative Asset Management (Oxford University Press, December 2011)
• Events: “Pension Risk Management & Governance: Challenges and Opportunity” (Hartford CFA Society, January 2012)
“Asset Allocation After the Crash” (Moderated)(NYSSA, November 2009)
“Pensions at Risk: A Meeting of Fiduciary and Financial Minds” (Moderated)(NYSSA, January 2009)
•`Competitions: Wildcard Division Winner of the BattleFin quantitative trading tournament for Fall-Winter 2012