SEC Proposes Rescinding Investment Adviser Pay-to-Play Rule
The proposal would eliminate Rule 206(4)-5’s two-year compensation ban, covered associate framework and third-party solicitor restrictions. Actual pay-to-play conduct would remain a potential antifraud and fiduciary-duty violation. On September 3, 2026, the US Securities and Exchange Commission (SEC) proposed rescinding Rule 206(4)-5 under the Investment Advisers Act of 1940 (Advisers […]
Primer: Management Fees in Private Equity and Venture Capital Funds
We are often asked about the “market” rate for management fees in actively managed private equity and venture capital funds. That question sounds simple, but it is usually not just a question about the headline percentage rate. This primer discusses mainstream private equity and venture capital funds, so to speak. […]
The Private Fund Issues Beneath Recent SEC Enforcement Cases
Recent enforcement actions brought by the Securities and Exchange Commission (SEC) involving private funds highlight more than the misconduct alleged in the complaints and settlement orders.[1] They also surface a variety of regulatory issues that can be easy to miss amid the headlines. Tucked beneath allegations of hidden markups and […]
Primer: Corporate Venture Capital Funds
We are often asked how corporate venture capital funds are structured – and how they differ from the mainstream venture capital funds we usually discuss in these primers. It is a fair question, and an underserved one. Corporate money is everywhere in the venture market in a limited partner capacity, […]
Primer: Continuation Funds in Private Equity and Venture Capital
We are often asked about continuation funds – what they are, why they have moved from the outskirts of the secondary market to the center of private markets liquidity, and what a manager who is considering one should expect the process to involve. When we wrote our primer on carried […]
Primer: Side Letters in Private Equity and Venture Capital Funds
We are often asked what side letters are, why they exist and how fund managers should think about them when raising a private equity or venture capital fund. The question sounds simple, but side letters sit at the intersection of fundraising leverage, investor regulation, tax sensitivity, operational administration, most favored […]
Primer: Handling Senior Partner Departures in Private Equity and Venture Capital Firms
We are often asked what a private equity or venture capital firm should do when a founder, senior investment professional or other important partner leaves the firm. Sometimes the departure is orderly. A founder retires after a long transition. A senior partner moves into an advisory role. A partner steps […]
Primer: Planning for Senior Partner Transitions in Private Equity and Venture Capital Firms
We are often asked how private equity and venture capital firms should think about the retirement or transition of founders, senior investment professionals and other long-serving partners. Sometimes the question is asked directly. A founder is approaching retirement age. A senior partner wants to step back from full-time investment activity. […]