Tag: disclosure obligations

Suggestions on Global Threshold Monitoring

On the heels of several European events focused on shareholder and position limit monitoring, we shifted to Miami, Florida and the Ascendant Compliance Solutions Strategies 2019 Spring Conference for another engaging session on the subject. (For an intro to the topic, see our previous blog post here.) In many ways the discussions proved to be … Continued

Do Your Fund Documents Clearly Disclose Receipt of Accelerated Monitoring Fees?

Somewhat more reminiscent of the broken-windows enforcement era, two affiliated private equity advisers managing billions settled with the SEC on charges that they failed to make pre-commitment disclosures in fund governing documents related to accelerated fees received from portfolio companies. Interestingly, according to the Settlement Order, the advisers had made some disclosures in fund documents … Continued


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CSS frequently publishes blog posts which are written by our team from their observations in the field, at conferences and through experiences with compliance professionals. These posts are designed to further knowledge and share industry best practices. Topics run the gamut, including Form ADV, cybersecurity, MiFID II, position limit monitoring, technology challenges and more. Complete and submit the brief form below to receive notifications when we publish new content.

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