While accounting standards, valuation frameworks and industry guidelines have been moving towards standardization of valuation principles, private equity (“PE”) fund managers still have substantial freedom when valuing their portfolio companies. For example, there is inevitable temptations to present interim performance numbers in a particularly favorable light when raising a follow-on fund or limiting write-downs during…

New anti-money laundering (“AML”) rules are coming for registered investment advisors (“RIA”). The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury, has proposed a rule that would subject registered investment advisors, including hedge funds and private funds, to rules very similar to those that banks have had to comply with for…

The SEC requires registered investment advisers to maintain a compliance program that implements a written code of ethics and policies and procedures to enforce them. Insider trading is a serious regulatory violation that can be avoided, provided clear and concise policy to control and contain the misuse of non-public material information. The COE is also…

The SEC’s Division of Investment Management recently released a Guidance Update which provides important guidance for investment advisors to mutual funds on managing the acceptance of gifts and entertainment from those doing or hoping to do business with the investment adviser. The guidance discusses the inherent conflicts of interest presented by the receipt of gifts…

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