Private Funds

Notice puts industry on the clock

First compliance deadlines take effect 60 days from Sept. 14

'The clock is ticking'

Compliance may not be a check-the-box exercise anymore, but you've still got to check the boxes

The adviser failed to distribute required audited financials

The audits were completed pursuant to the International Standards on Auditing, not U.S. GAAS requirements; and the auditor was not registered with the PCAOB, resulting ...

The adviser purported to rely on the exception to the qualified custodian requirement but did not obtain an audit of each of the Funds and ...

The firm also did not properly describe the status of its fund’s financial statement audits when filing its Forms ADV and did not update certain ...

The adviser failed to maintain securities of certain private equity funds that it advised with a qualified custodian

He failed to take necessary steps to do so despite being on notice of the rule’s requirements and was aware of the ongoing failures in ...