SEC Private Fund Adviser Enforcement FY 2024 Highlights
The cases brought by SEC’s Division of Enforcement during fiscal year 2024 underscore the agency’s focus over the last several years on post-commitment management fee calculations, recordkeeping and off-channel communications, fee and expense disclosures, controls related to material non-public information and conflicts of interest generally. We highlight below several notable cases and sweeps conducted over […]
Julie Riewe, Kristin A. Snyder, and Robert Kaplan are Partners at Debevoise & Plimpton LLP. This post is based on a Debevoise memorandum by Ms. Riewe, Ms. Snyder, Mr. Kaplan, Andrew Ceresney, Charu Chandrasekhar, and Sasha Semach.
The cases brought by SEC’s Division of Enforcement during fiscal year 2024 underscore the agency’s focus over the last several years on post-commitment management fee calculations, recordkeeping and off-channel communications, fee and expense disclosures, controls related to material non-public information and conflicts of interest generally. We highlight below several notable cases and sweeps conducted over the past year involving these issues. In light of the U.S. presidential election results, however, we expect enforcement activity involving private fund advisers to slow in certain of these areas.
