Custody procedures, marketing restrictions, recordkeeping, compliance infrastructure, and SEC examination readiness for operating funds.
The custody rule is one of the most consequential compliance obligations for private fund managers. If you have custody of client assets, you must either submit to surprise examinations or undergo an annual audit of each fund.
The SEC marketing rule governs how investment advisers present performance, use testimonials, and advertise their services. Understanding the requirements is essential for any fund manager producing pitch decks, DDQs, or investor communications.
Missing a deadline does not just create a compliance gap. It can trigger penalties, loss of exemptions, or LP dissatisfaction. This calendar covers the key recurring dates for private fund managers with calendar-year funds.
Registered investment advisers must maintain specific books and records under the Advisers Act. Maintaining thorough records is standard practice for all fund managers and is expected by institutional LPs and auditors.
SEC examinations can happen to both RIAs and ERAs. Knowing what the SEC looks for and how exams work helps you avoid the most common deficiency findings.
Registered investment advisers must adopt a code of ethics under the Investment Advisers Act. Even ERAs that are not technically subject to this requirement should adopt one, as institutional LPs expect it during operational due diligence.
Institutional LPs will ask for your compliance manual during due diligence. Written compliance policies document how your firm handles conflicts of interest, personal trading, information barriers, and regulatory obligations.
If you charge performance-based compensation, your investors may need to meet the qualified client standard. The threshold is higher than accredited investor status, and the rules vary based on your registration type.
Remote work has created new compliance complexity for fund managers. If your investment team works from multiple states, each state may trigger separate registration or notice filing requirements.
Fund managers handle sensitive investor data and valuable investment information. Cybersecurity and data privacy are operational risks that require documented policies, practical protections, and adequate insurance coverage.
Fund managers can encounter material nonpublic information through board seats, management meetings, co-investor relationships, and deal processes. Insider trading violations carry severe penalties, including criminal prosecution.
Capital Company handles formation, compliance filings, and back-office operations so you can focus on investing.