Doug Cornelius on compliance for private equity real estate
Alumni Ventures Group is New Hampshire-based venture capital fund manager. It raised dozens of funds to pool capital and invest it in small companies. From 2016 through 2020, in marketing the funds the manager said its management fee was the “industry standard ‘2 and 20’.” The funds had a 10-year life. Most of us realize … Read more »
FINRA released regulatory notice 22-10 that said it generally considers the role of compliance chief an advisory position rather than a supervisory one. Rule 3110 (Supervision) imposes specific supervisory obligations on member firms. The responsibility to meet these obligations rests with a firm’s business management, not its compliance officials. The CCO’s role, in and of … Read more »
I’m a cyclist. I like cycling for my commute, fast rides, rides in the suburbs, fat biking in the snow. I like watching competitive cycling: men’s and women’s races. I watch more women’s racing because of Kathryn Bertine. Kathryn Bertine details her activism for equality with women’s cycling in Stand. It’s a memoir detailing the ups … Read more »
At its open meeting on February 9, the Securities and Exchange Commission offered up a buffet of proposed regulations of private funds. It’s really an all-you-can eat buffet with six proposed changes across a variety of areas. The SEC wants private funds to send out quarterly statements to private fund investors. It doesn’t seem that … Read more »
Calculating fund fees during the commitment period is usually easy for most private equity funds. Take the committed capital and multiply it by the applicable fee percentage. After the commitment period, the calculation often gets more complicated. Most funds have some reduction to actual capital deployed with deductions for write-downs and partial realizations. Global Infrastructure … Read more »
I assume some compliance officers often get involved in their firm’s retirement plans. If so, you may want to take a look at a decision last week by the US Supreme Court: Hughes v. Northwestern University. The case is a lawsuit by employees of Northwestern against the school and trustees of the school’s retirement plans. This … Read more »
On January 27, the SEC’s Division of Examinations published a Risk Alert on the EXAMS staff Observations from Examinations of Private Fund Advisers. The Risk Alert is labeled as a follow up to the 2020 Observations from Examinations of Investment Advisers Managing Private Funds and the 2017 The Five Most Frequent Compliance Topics. The EXAMS … Read more »
On Wednesday February 9 the SEC has a full agenda for its meeting and fund managers should pay attention. Here are the matters to be considered: The Commission will consider whether to propose rules and amendments under the Investment Advisers Act of 1940 (“Advisers Act”) for private fund advisers and whether to propose amendments to … Read more »
It’s been a decade since the SEC and FSOC pushed Form PF on to private funds. The SEC has decided it wants more data and has proposed an amendment to Form PF. The big change is next day reporting for key events by Large Hedge Fund Advisers and Private Equity Funds For large Hedge Funds: certain … Read more »
This insider trading case caught my attention because of the local setting. David Forte is an officer with the Needham Police Department. That’s the next town over from my town. I’m such a homer. One of Forte’s brothers was the Chief Information Officer at Analog Devices. The brother discovered that Analog was going to buy … Read more »