Month: September 2026
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 […]