Five Steps That CCOs Can Take to Avoid Supervisory Liability, and Other Hedge Fund Manager CCO Best Practices

Participants at FRA’s Private Investment Funds Compliance Master Class, held on February 17, 2015 in New York City, addressed testimonials and past-specific recommendations in hedge fund marketing; whether performance should be presented net or gross of fees; presenting performance under different fee structures; use, placement and monitoring of third-party news articles; broker registration of in-house marketers and marketing departments; reverse solicitation and remuneration under AIFMD; bad actor rule compliance; three theories of CCO liability; three categories of enforcement actions involving CCOs; and five steps that CCOs can take to avoid liability.  See also “Stroock Seminar Identifies Five Strategies for Mitigating the Risk of Supervisory Liability for Hedge Fund Manager CCOs,” Hedge Fund Law Report, Vol. 7, No. 2 (Jan. 16, 2014).

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