Private Fund Reform Proposal Comments: Concerns About Specific Requirements (Part Three of Three)

When the SEC proposed extensive private fund reforms (Proposal) in February 2022, hundreds of individuals and groups involved with the private funds industry submitted comment letters during an extended comment period. This article, the last in our three-part series presenting key takeaways from a targeted cross-section of more than 300 comment letters submitted on the Proposal, covers concerns about specific requirements in the Proposal, particularly the bans on engaging in certain practices and providing preferential treatment to certain investors. The first article summarized general concerns raised in the comment letters about the SEC’s authority to make the proposed changes, as well as the scope, intent and impact of the Proposal. The second article discussed three requests made by commenters. See our two-part series on the Proposal: “General Observations” (Apr. 7, 2022); and “Rule‑Specific Concerns and Next Steps” (Apr. 14, 2022); as well as “Overview of the Proposal and the Importance of Industry Comments” (March 17, 2022).

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