Sarah Bessin
Sarah Bessin is a securities lawyer who serves as senior associate general counsel for U.S. regulatory affairs and investment management at the asset manager Franklin Templeton, having previously practiced at a law firm and held positions at the SEC and the Investment Company Institute.
Contents7 sections
Key facts
2003Practicing at Shearman & Sterling
Sarah Bessin spent more than five years in private practice at Shearman & Sterling LLP (now A&O Shearman). In September 2003, staff of the National Association of Securities Dealers (NASD) addressed an interpretive letter to her, then a lawyer in the firm’s Washington office, on secondary market trading in shares of a Fidelity exchange-traded open-end fund.[1][2]
February 28, 2025Meeting With the SEC Crypto Task Force
On February 28, 2025, Franklin Templeton met with SEC Crypto Task Force staff on issues related to the regulation of crypto assets, and Sarah Bessin was listed among the anticipated attendees as senior associate general counsel.[3]
March 2026Remarks on Alternatives in 401(k) Plans at the IAA Compliance Conference
In March 2026, as Franklin Templeton’s senior associate general counsel for U.S. regulatory affairs and investment management, she took part in a panel at the Investment Adviser Association (IAA) Compliance Conference in Washington. She said the main obstacle to including alternatives in 401(k) plans is litigation risk rather than operations, and that the prior year’s executive order and a likely Department of Labor proposal were unlikely to change that.[4][1]
October 9, 2026Meeting With the SEC Crypto Task Force on Tokenized Funds
On October 9, 2026, Franklin Templeton representatives met with staff of the U.S. Securities and Exchange Commission (SEC) Crypto Task Force, and Sarah Bessin was listed among Franklin Templeton’s anticipated attendees as senior associate general counsel. The agenda covered the company’s digital assets business (including the FOBXX fund), the SEC’s proposed Innovation Exemption, and Investment Company Act of 1940 issues, such as whether tokenized money market fund shares traded in pairs with tokenized NMS stocks on a trading system would need relief from Section 22(d) and Rule 22c-1.[5]
Undated: Education and Earlier Positions
She received a B.A. from the University of Michigan and a J.D., cum laude, from the University of Michigan Law School. Before joining Franklin Templeton, she served as deputy general counsel at the Investment Company Institute and held several positions at the SEC, including assistant director of the Office of Investment Adviser Regulation.[1]
Related Organizations, Websites, and Public Accounts
Franklin Templeton: Official website: https://www.franklintempleton.com/ (opens in a new window)[6]
Sources
- 2026 Investment Adviser Compliance Conference Speakers (opens in a new window)
- Interpretive Letter to Sarah A. Bessin, Esq., Shearman & Sterling LLP (opens in a new window)
- MEMORANDUM To: Crypto Task Force Meeting Log From: Crypto Task Force Staff Re: Meeting with Franklin Templeton (opens in a new window)
- CITs Could Ease Path to Private Markets in 401(k)s (opens in a new window)
- Memorandum: Crypto Task Force Meeting Log — Meeting with Franklin Templeton (October 9, 2026) (opens in a new window)
- Franklin Templeton (opens in a new window)