After nearly 18 months of consideration, the SEC has finalized its Private Fund Adviser Rule. The Rule represents the most significant shift in SEC regulation of private funds since the implementation of Dodd-Frank, and its wide-ranging requirements will affect both US and Non-US Fund Managers (including many entities previously exempt from SEC regulation).
New requirements include:
Significant restrictions on side letters and co-investment fees;
Regulation regarding GP clawback arrangements and GP-led secondaries; and
Significant standardized quarterly investor reporting.
Upon the Rule’s compliance dates, it will retroactively affect existing fund arrangements, and managers across a range of asset classes and strategies will need to take action.
Fill out the form to listen in to hear first impressions and practical compliance tips from Baker McKenzie Funds lawyers Karl Egbert, Shusmita Chowdhury, Zlatomira Simeonova, Kameron Hillstrom, and Deborah You.