New SEC Rules for Private Fund Managers (including Key Takeaways and Summary Chart) (August 2023)

Simon RivelesCompliance, Custody Rule, Investment Adviser Registration, Investment Advisers, SEC

On August 23, 2023, the U.S. Securities and Exchange Commission (“SEC”) implemented heavily anticipated private fund reforms (the “Private Funds Rules” or the “Rules”) promulgated under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Although the Rules are far less “mandate-driven” than those originally proposed in February 2022, the Rules nevertheless impose significant disclosure (and in some cases, operational) requirements that all …