SEC Sanctions Private Fund Sponsor for Using Unlicensed Broker to Sell Private Fund Interests

29 March 2013
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Key takeaways 

  • Legal or natural persons receiving transaction-based compensation in connection with marketing private fund interests need to register as brokers under Section 15(a) of the Securities Exchange Act of 1934. 
  • Private fund sponsors should be aware of a marketer's activities and registration status to ensure that both are appropriate in scope.