Tag: disclosure obligations

10 Compliance Tips for Starting 2020 Off on the Right Foot

No rest for the weary. With the new year upon us, our attention turns to new budgets, change and planning. With renewed energy as we roll into January thaw, we worry if our compliance program is ready. To give you a leg up, here are 10 tips for investment adviser and broker-dealer compliance teams for … Continued

Compliance Lessons Learned in 2019

Now that we are in mid-January, a few things are evident. We have likely broken one or more New Year’s resolutions, the effect of any rest over the holidays has worn off and we need to complete our annual compliance reviews for 2019 and firm up our 2020 plans. While I don’t have solid advice … 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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