Ellen Paulus

Ellen Paulus specializes in investments, financial markets, market manipulation and antitrust claims, and valuation. A leader in Cornerstone Research’s investments, private equity (PE), and venture capital (VC) practices, Dr. Paulus consults to asset managers, broker-dealers, and PE and VC sponsors on matters involving the performance, pricing, trading, and portfolio allocation of mutual funds, exchange-traded funds (ETFs), and structured products. She has analyzed alleged collusion and manipulation in foreign exchange (FX), corporate bond, and precious metals markets.

Dr. Paulus supports clients and experts through all phases of litigation, including mediation, deposition, class certification, and trial. She has published research in the Journal of Empirical Finance.

Consulting Magazine named Dr. Paulus to its 2025 list of Women Leaders in Consulting, recognizing her as a Future Leader who demonstrates “above-the-call” leadership benefiting her organization and current and future peers.

Investments

Dr. Paulus has assessed various issues arising in portfolio management firms. She has supported firms in regulatory investigations led by the Securities and Exchange Commission (SEC) and the U.S. Department of Justice (DOJ). She has worked on class action litigation matters involving Section 36(b) of the Investment Company Act of 1940 and the Employee Retirement Income Security Act (ERISA).

Dr. Paulus has extensive experience with trading and portfolio allocation, pricing of mutual funds, ETFs, closed-end funds, and a range of structured products. Her expertise includes:

• Analyzing portfolio allocations to address claims of cherry-picking
• Analyzing mutual funds’ performance, fee, scale, and profitability data to address claims of excessive fees under Section 36(b)
• Conducting valuation of odd-lot holdings of securities by ETFs
• Analyzing trading in ETF basket securities by an authorized participant
• Evaluating defined contribution plan performance and fees, as well as individual-level transaction data, in the context of ERISA
• Assessing performance attribution and portfolio risk for a family of corporate and municipal bond funds
• Identifying cross-trades in mutual fund transaction data and estimating appropriate remediation under Rule 17a-7 of the Investment Company Act of 1940
• Evaluating proposed SEC rulemaking on sales practices on behalf of an ETF sponsor
• Conducting valuation of structured products, including the tranches of synthetic collateralized debt obligations (CDOs)
• Conducting credit risk assessments for a variety of fixed income and hybrid instruments

Collusive conduct in financial markets

Dr. Paulus has assessed the alleged market manipulation of bid-ask spreads, asset prices, and benchmark prices in FX markets; over-the-counter (OTC) markets for corporate bonds; and the primary market for ETFs. She has worked with major financial institutions to analyze large transaction-level datasets and conducted forensic analyses of specific trading episodes.

Dr. Paulus has addressed antitrust issues arising in commercial litigation as well as regulatory and internal investigations. Her experience includes:

• Addressing alleged market manipulation and collusive conduct in FX markets, both in the contexts of class certification and liability and damages
• Consulting on multinational regulatory investigations into the alleged manipulation of precious metal derivatives
• Analyzing alleged manipulation of a pricing algorithm for corporate bonds in the context of internal investigations

Valuation, PE, and VC

As a leader in Cornerstone Research’s PE and VC practice, Dr. Paulus has extensive experience performing valuations of:

• Common and preferred equity interests in venture-backed private companies under different methodologies, including discounted cash flow (DCF) and option pricing models
• Equity interests in PE and VC general partnerships, including valuation of carried interest
• Private credit and hybrid capital interests

Dr. Paulus also consults on customs and practices related to PE and private credit deals, including investment and valuation due diligence. Her experience in valuation, PE, and VC issues includes arbitrations, as well as matters in tax court and before the Delaware Court of Chancery.