Proposed SEC Private Fund Advisers Rules

On February 9, 2022 the SEC released proposed rules that would apply to private fund advisers.  The proposed rules are titled “Private Fund Advisers: Documentation of Registered Investment Adviser Compliance Reviews.” Comments letters were due on April 25, 2022. Submitted comments can be seen here.

ILPA has engaged with LPs, other industry participants and the SEC regarding the impact that the proposed rules may have on the industry. ILPA is broadly supportive and aligned with the aims underlying the SEC proposals. ILPA has submitted comments on every provision contained within the proposed rule.

ILPA looks forward to continuing to engage with the SEC as it works towards a final rule proposal. Email [email protected] with questions regarding ILPA's response to the proposed rule.

ILPA Final Comment Letter – ILPA’s comment letter submitted to the SEC on April 25, 2022.

ILPA Position Summary – ILPA’s Position Summary describe ILPA’s view point on each provision in the proposed rule

March 22 Roundtable Materials – On March 22, ILPA held a members-only roundtable to discuss LP responses to specific provisions within the proposed rule

March 8 Webcast Link – On March 8, ILPA held a webcast featuring a conversation between Melissa Harke, Senior Special Counsel at the SEC and Heather Traeger, COO at Texas TRS to discuss the intent behind the rule provisions

Statement from ILPA's CEO Steve Nelson regarding the proposed rules – ILPA’s CEO expressed appreciation that the SEC has proposed rules with the goal of strengthening transparency and alignment of interest in private markets