Practical Lessons From OCIE’s Risk Alert on Compliance Issues for Private Fund Managers (Part One of Two)

A panel at the recent GAIM Ops Connect conference offered an in-depth look at the recent risk alert issued by the SEC’s Office of Compliance Inspections and Examinations on its observations from examinations of private fund managers. Suzan Rose, senior adviser to the Alternative Investment Management Association, moderated the discussion, which featured Andrew Genser, GC at Viking Global Investors; Owen Schmidt, partner at Schulte Roth & Zabel; and Ryan VanGrack, senior deputy GC at Citadel. The core insights explored during the presentation are discussed in this two-part series. This first article provides an overview of the risk alert and covers the discussion on conflicts relating to allocation of investments and preferred equity; and co‑investments. The second article will evaluate the discussion on fee and expense allocations; valuation; insider trading controls; and offshore directors. See our two-part coverage of the risk alert: “Focus on Conflicts; Fees and Expenses; and MNPI” (Aug. 6, 2020); and “Key Takeaways for Managers” (Aug. 13, 2020).

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