The purpose of this paper is to remind sponsors and managers of hedge funds and private funds (including private equity and venture capital funds) of certain “best practices” that they should consider.
The paper offers considerations concerning: preparation and review of written compliance and procedures documents; updating Form ADV; other regulatory filings including blue sky filings, Form 13F, Schedule 13D/13G, Forms 3, 4, and 5, and other forms; audited financial statements; Schedule K‐1; offering document updates; fee deferral arrangements; CFTC requirements; liability insurance; employee training; and other annual requirements including privacy policies and new issues.
Amid recent rapid growth in hedge funds and private equity funds and volatility in the financial markets, it is more important than ever to ensure that regulatory filings and compliance policies and procedures are properly documented and followed.
This paper provides a brief, useful checklist from experienced securities lawyers, but a comprehensive guide or legal advice concerning any specific situation.
Giordano, S.M., Goldman, R.A., Leonard, R.G. and Mavrides, M.F. (2008), "Recommended annual review for hedge funds and other private fund managers", Journal of Investment Compliance, Vol. 9 No. 2, pp. 35-39. https://doi.org/10.1108/15285810810886162
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