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Takeaways from ILPA’s NAV Loan Guidance

The differing waiver rules governing the fragile attorney-client privilege and the robust work product doctrine protection predictably create stark differences when family members communicate with each other. This type of...more

Fifth Circuit Vacates Private Fund Adviser Rules

Yesterday, a three-judge panel of the United States Court of Appeals for the Fifth Circuit unanimously vacated the Private Fund Adviser Rules adopted by the Securities and Exchange Commission (which we previously summarized)...more

NAV Loans in Private Funds: Considerations for Managers and Investors

Loans to private investment funds based on the net asset value of their respective portfolio investments (that is, total assets of such a fund less its liabilities) have become dramatically more popular in recent years, as...more

Summary of the SEC’s 2024 Examination Priorities for Registered Investment Advisers

Yesterday, the United States Securities and Exchange Commission (the “SEC” or the “Commission”) Division of Examinations released its examination priorities to inform market participants of the key topics and priorities that...more

Analysis of the SEC’s New Quarterly Reporting Requirements for Registered Investment Advisers

On August 23, the United States Securities and Exchange Commission (the “SEC” or “Commission”) adopted rules and rule amendments (the “PFA Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”) that impose new...more

SEC Adopts New Rules Governing Private Fund Advisers

Yesterday, the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) adopted rules and rule amendments (the “PFA Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”) that impose new...more

Implications of the 2023 Form PF Amendments

After the 2008 financial crisis, the U.S. Securities and Exchange Commission (the “SEC” or “Commission”) introduced the Form PF (Private Fund), which the SEC intended to serve as a tool for monitoring and assessing systemic...more

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