The Before and After of Private Fund Adviser Reform: A Comparison of the Final Rule to the Proposal

23 August 2023
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Earlier today, the Securities and Exchange Commission (the “SEC”) adopted final rules applicable to investment advisers to private funds. Amended Rules 204-2 and 206(4)-7, and new Rules 206(4)-10, 211(h)(1)-1, 211(h)(1)-2, 211(h)(2)-1, 211(h)(2)-2, and 211(h)(2)-3 (collectively the “Adopted Rules”) usher in a host of new regulatory requirements applicable to private funds unlike any seen before by the industry.