Peter Sullivan
About Peter M. Sullivan
Peter M. Sullivan serves as Chief Legal Officer, Vice President and Assistant Secretary of BNY Mellon Strategic Municipal Bond Fund, Inc. (DSM) and has been an officer of the Fund since 2019; he has served as Chief Legal Officer since July 2021. He is 57 years old and, in parallel, is Chief Legal Officer of BNY Mellon Investment Adviser, Inc. and Associate General Counsel of The Bank of New York Mellon (BNY) since July 2021. He is an officer of 47 registered investment company complexes (comprised of 103 portfolios) managed by the Investment Adviser or an affiliate, reflecting a platform-wide legal leadership role rather than a DSM-specific compensation structure. DSM’s filings do not provide officer-level performance metrics (e.g., TSR, revenue/EBITDA growth) tied to Mr. Sullivan’s role.
Past Roles
| Organization | Role | Years | Strategic impact |
|---|---|---|---|
| The Bank of New York Mellon | Managing Counsel | Mar 2009 – Dec 2020 | Senior legal counsel to BNY business units; foundation for subsequent associate GC role supporting Investment Adviser and funds platform |
| The Bank of New York Mellon | Senior Managing Counsel | Dec 2020 – Jul 2021 | Elevated legal leadership immediately prior to assuming CLO responsibilities at the Investment Adviser |
External Roles
| Organization | Role | Years | Notes |
|---|---|---|---|
| BNY Mellon Investment Adviser, Inc. | Chief Legal Officer | Jul 2021 – Present | Oversees legal for the Investment Adviser; concurrent with DSM CLO role |
| The Bank of New York Mellon | Associate General Counsel | Jul 2021 – Present | Enterprise legal leadership alongside fund advisory responsibilities |
| RIC complexes managed by the Adviser/affiliates | Officer of 47 investment companies (103 portfolios) | As of 2025 | Platform-wide officer responsibilities beyond DSM |
Fixed Compensation
DSM’s proxy statements disclose compensation for directors, not for officers; no salary, target bonus, or actual bonus data for Mr. Sullivan is reported in DSM filings. Officers are identified as personnel of the Investment Adviser/BNY (e.g., “Chief Legal Officer of the Investment Adviser and Associate General Counsel of BNY”), and the Part II officers section provides biographies without compensation tables.
| Component | 2024 | 2025 YTD | Notes |
|---|---|---|---|
| Base salary | Not disclosed in DSM filings | Not disclosed in DSM filings | DSM proxies present only board (director) fees, not officer pay |
| Target bonus % | Not disclosed in DSM filings | Not disclosed in DSM filings | No officer bonus framework disclosed by DSM |
| Actual bonus paid | Not disclosed in DSM filings | Not disclosed in DSM filings | Not reported by DSM |
Performance Compensation
DSM does not disclose officer equity or option awards, performance metrics, or vesting terms for Mr. Sullivan. The proxy’s compensation sections cover director retainers/fees and do not include RSUs/PSUs/options for officers.
| Incentive type | Metric(s) | Weighting | Target | Actual | Payout | Vesting |
|---|---|---|---|---|---|---|
| RSUs/PSUs | Not disclosed | — | — | — | — | — |
| Stock options | Not disclosed | — | — | — | — | — |
| Cash STI | Not disclosed | — | — | — | — | — |
Equity Ownership & Alignment
| Item | Detail |
|---|---|
| DSM beneficial ownership | As of April 10, 2025, none of the Fund’s Directors or officers (including Mr. Sullivan) owned any Common Stock or VMTP Shares of DSM |
| Vested vs. unvested shares | Not applicable at DSM (no holdings disclosed) |
| Options (exercisable/unexercisable) | Not disclosed at DSM; no officer option data reported |
| Shares pledged as collateral | No pledging disclosed; officers held no DSM shares as of April 10, 2025 |
| Stock ownership guidelines | Not disclosed for officers in DSM filings |
| Compliance status | Not disclosed |
Employment Terms
| Term | Disclosure |
|---|---|
| DSM officer roles | Chief Legal Officer, Vice President and Assistant Secretary (officer since 2019; CLO since July 2021) |
| Term of office | Indefinite until a successor is elected and qualified (standard for DSM officers) |
| Employer/affiliation | Chief Legal Officer of BNY Mellon Investment Adviser, Inc.; Associate General Counsel of BNY |
| Contract term/expiration | Not disclosed in DSM filings |
| Severance / Change-of-control | Not disclosed in DSM filings |
| Non-compete / Non-solicit | Not disclosed in DSM filings |
| Clawbacks / tax gross-ups | Not disclosed in DSM filings |
| Officer address of record | 240 Greenwich Street, New York, NY 10286 (fund officer address) |
Investment Implications
- Alignment and trading signals: DSM reports that officers (including Mr. Sullivan) held no DSM equity as of April 10, 2025, eliminating insider selling pressure risk and providing no officer-level insider-trading signals for DSM. However, lack of ownership also limits direct “skin-in-the-game” alignment at the Fund level.
- Compensation transparency: DSM proxies disclose board compensation but do not provide officer salary/bonus/equity data; Mr. Sullivan’s compensation is tied to his roles at the Investment Adviser/BNY, not directly to DSM performance, making pay-for-performance assessment at the Fund level impracticable.
- Retention considerations: Mr. Sullivan’s role spans the broader BNY platform (officer of 47 investment companies, 103 portfolios), and DSM officers serve indefinite terms; no DSM-specific retention agreements or severance protections are disclosed, implying standard corporate retention levers at the Adviser level rather than Fund-level constructs.
- Governance and disclosure quality: DSM filings consistently identify officers, delineate board compensation, and affirm no officer share ownership as of the reporting date; absence of officer comp detail is typical for registered funds where officers are employees of the external adviser.