Aaron Gilbride
  1. Counsel

Mr. Gilbride is counsel in Davis Polk's Corporate Department, practicing in the Investment Management Group. He advises investment advisers, registered funds, private funds, fund directors and financial institutions on matters under the federal securities and banking laws. 

Prior to joining Davis Polk, Mr. Gilbride was Branch Chief in the Chief Counsel's Office of the Division of Investment Management at the Securities and Exchange Commission. His office was responsible for issuing no-action letters, interpretive letters and exemptive relief, as well as taking other staff positions, under the securities laws that apply to investment companies and investment advisers. In this capacity, he worked extensively with the SEC’s Office of Compliance Inspections and Examinations and Division of Enforcement on a wide variety of examinations and enforcement actions, with a particular focus on investment advisers and private funds. 

In his time at the SEC, Mr. Gilbride also served as Senior Counsel to the Director of the Division of Investment Management and was one of the Division's principal staff members on the Volcker Rule Interagency Group, focusing on covered fund issues.  

Prior to joining the SEC, Mr. Gilbride worked as an associate in the investment management group of another law firm and as a staff member in the U.S. House of Representatives.

Bar Admissions

  • District of Columbia
  • State of New York


  • B.Sc., Finance, Miami University, 2003
  • J.D., American University, Washington College of Law, 2009
    • Senior Staff, American University Law Review

Professional History

  • Counsel, Davis Polk, 2019-present
  • Securities and Exchange Commission, Division of Investment Management
    • Chief Counsel's Office: Branch Chief, 2018-2019; Acting Branch Chief, 2017; Senior Counsel, 2013-2017
    • Office of the Director: Senior Counsel to the Director, 2017-2018
  • Associate, Stadley Ronon Stevens & Young, 2009-2013
  • Congressional Aide, U.S. House of Representatives, 2003-2007