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Disclosure Requirements › Securities and Exchange Commission (SEC) › Internal Rate of Return (IRR)

Dorsey & Whitney LLP

The SEC Issues Marketing Rule FAQ on Calculating Gross and Net Performance

Dorsey & Whitney LLP on

The staff (“Staff”) of the SEC’s Division of Investment Management recently issued a new FAQ (the “FAQ”) on Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 in which the Staff confirmed that the...more

Goodwin

SEC Issues Updated Marketing Rule FAQ on IRRs for Funds With Subscription Facilities

Goodwin on

On February 6, 2024, the staff of the Securities and Exchange Commission (SEC) issued an updated FAQ with respect to the Marketing Rule (Rule 206(4)-1) under the Investment Advisers Act of 1940 (the Advisers Act). This FAQ...more

Jones Day

SEC's Unwavering Focus on Disclosure of Valuation Methods and Calculation of IRRs by Fund Sponsors

Jones Day on

The recent SEC subpoena of a fund sponsor for additional information concerning how it calculates internal rates of return ("IRRs") indicates that investment performance disclosure, and specifically the calculation of IRRs,...more

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