When a fund manager suspends withdrawals or redemptions by investors in its fund, the goal is usually to lift the suspension eventually and as soon as is reasonably practicable given the circumstances that led to it. A suspension is essentially a pause, with the alternative being liquidation of the fund. There are factors, however, that a manager should consider when deciding when and how to lift a suspension. Moreover, managers should take certain steps now to prepare for possible suspensions in the future – and not wait until conditions become dire. This three-part series explores the process of suspending withdrawals. This third article explains the process for lifting a suspension and actions managers should take today to prepare for if they should need to consider a suspension in the future. The first article
discussed suspensions during the 2008 financial crisis compared to the current pandemic; reasons a fund manager may consider imposing a suspension; the downsides of doing so; and the SEC’s view of suspensions. The second article
examined the process by which a fund manager may suspend withdrawals. See “Lock-Ups and Investor-Level Gates Prevalent in New Hedge Funds
” (Mar. 23, 2017).