SEC Adopts Private Fund Rules, Instructing All Investment Adviser Firms to Document Annual Reviews Now

On August 23, 2023, the Securities and Exchange Commission adopted new rules and amendments concerning the regulation of private fund advisers. Although the new Private Fund Rules impact only those investment advisers with private fund offerings, buried in at the end of the rulemaking is an amendment to the Compliance Rule. Previously, registered investment advisers were required to review their compliance programs annually.  The rule was silent on whether documentation of the review was required. This is no longer the case. With the adoption of the Private Fund Rules, the amendment now requires registered investment advisers to document their annual review in writing. 

For more information on the requirements, see the Rule release here.

We  are here to assist you with the Annual Review process, regardless of your firm's size or complexity. Whether you're looking for a one-time third-party review or establishing an ongoing partnership with someone who understands your business model, we can help deliver consistent results.

Bates Compliance, a division of Bates Group, brings tailored compliance consulting solutions to our investment adviser, broker-dealer, and hybrid firm clients on an as-needed or ongoing basis.  Our compliance team includes senior compliance staff and former regulators who test policies, procedures, supervisory and compliance processes, recommending changes and best practices to enhance compliance and supervisory systems, and to remediate the results of regulatory and litigation findings.