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SEC Proposed Private Fund Rules: Overview of the Proposal and the Importance of Industry Comments (Part One of Three), Private Equity Law Report

May 24, 2022

The first article in a three-part series addressing the US Securities and Exchange Commission’s (SEC’s) proposed rules for the private funds space explains the types of funds impacted by the proposal, provides an overview of the seven rules and rule amendments contained in the proposal, and discusses the importance of comments on the proposal by private fund managers.

In discussing the impact of the timing and length of the comment period, partner Christine Lombardo told Private Equity Law Report that the “SEC has released five pieces of significant proposed rulemaking and rule amendments with overlap for the private fund adviser industry at about the same time: the Proposal, Form PF, beneficial ownership, cybersecurity and short sale disclosures. All private fund managers could potentially be impacted by this rulemaking.”

Christine noted that with a shorter comment period and the multiple rulemakings, “it does seem like industry resource constraints are inevitable.”

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