SEC Enforcement Against Private Equity Advisers Continues

18 December 2018
View Debevoise Update
Key takeaways:
  • Advisers who allocate internal employees’ expenses to fund clients should review their pre-commitment disclosures to ensure that such allocation is expressly disclosed, and that the process for making the allocation is operational, well-documented, and disclosed.
  • Advisers should also review their compliance policies and procedures to ensure that they adequately address expense allocation issues and other potential conflicts of interest, particularly those that arise when firm principals invest in or make loans to businesses that provide services to the funds.