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Are Your Employees Now “Knowledgeable”? New SEC Guidance for Private Fund Managers
6 March 2014
A recent SEC no-action letter updates guidance on the types of employees who can be deemed “knowledgeable employees” under the private fund provisions of the Investment Company Act.
The new guidance clarifies that employees who serve a policy-making function (even if as part of a group) may be treated as knowledgeable employees. The new guidance also provides greater flexibility in determining whether an employee contributes materially to the investment activities of the fund.
Fund sponsors may wish to review their policies and procedures for identifying “Knowledgeable Employees” based on this guidance.
Jennifer J. Burleigh
Michael P. Harrell
David J. Schwartz
Rebecca F. Silberstein
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