ThreeImportantDatesForTheAssetManagementIndustry
The compliance dates for recently adopted rules extending to “private-fund advisers” (“PFAs”) 1 are now known following their publication in the Federal Register [IA-Release No. 6383, 88 F.R. 63206 (Sept. 14, 2023)]. The rule package under the Investment Advisers Act of 1940 (“Advisers Act”) includes the following requirements: (i) production and delivery of quarterly customer statements; (ii) the annual audit of the financial statements of private investment funds; (iii) production and delivery of fairness or valuation opinions in adviser-led secondary market transactions; (iv) prescriptive conflicts management in the context of five specific restricted activities; (v) prescriptive conflicts management in cases of preferential treatment of selected investors; (vi) review and documentation of an annual compliance review – a requirement that extends to all investment advisers, not only PFAs; and (vii) the maintenance of books and records related to the rules. ...
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