News & Insights: Private Fund

SEC’s 2027 Exam Priorities: What Your Compliance Program Needs to Strengthen

On October 23, the SEC’s Division of Examinations released its 2027 Examination Priorities. Conflicts of interest, private funds, Super Intelligence (SI), cybersecurity, and Regulation S-P are among the focus areas. Here’s what examiners will look for and the steps advisers should take to strengthen their compliance programs now.

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SEC’s 2027 Exam Priorities: What Your Compliance Program Needs to Strengthen

On October 23, the SEC’s Division of Examinations released its 2027 Examination Priorities. Conflicts of interest, private funds, Super Intelligence (SI), cybersecurity, and Regulation S-P are among the focus areas. Here’s what examiners will look for and the steps advisers should take to strengthen their compliance programs now.

The Long-Awaited Custody Rule Proposal: What a Modernized Rule Could Mean for Crypto, Private Funds, and Investment Advisers

The SEC’s October 2026 Custody Rule proposal creates a compliant pathway for advisers to hold crypto assets, eases private fund audit requirements, and codifies years of no-action guidance. Here’s what it means for your firm.

Form PF Compliance Date Extended a Fourth Time to July 2027

The SEC and CFTC have pushed the Form PF amendments compliance date back again, from October 1, 2026, to July 1, 2027. It’s the fourth extension of the rule. Here’s what it means for private fund and hedge fund advisers.

SEC Proposes to Simplify Form PF: What Fewer Filers Means for Fund Managers

On April 20, 2026, the SEC and CFTC jointly proposed amendments to Form PF that would drastically reduce both the number of filers and the specific requirements for reporting that have expanded through prior amendments.

SEC Valuation Enforcement Case: A Warning for Private Fund Managers

On February 25, 2026, the SEC announced settled charges against an investment adviser for selling loans to private fund clients without determining whether those trades were at fair market value. Lack of a fair market value determination was contrary to the advisory agreements and other disclosures to private fund investors.

CFTC No-Action Relief: Do Private Fund Managers Still Need CPO Registration?

On December 19, 2025, the Commodity Futures Trading Commission’s Market Participants Division (“MPD”) announced a no-action letter stating the MPD will not recommend the CFTC initiate an enforcement action against firms registered as investment advisers with the SEC, who operate commodity pools privately offered solely to sophisticated investors known as qualified eligible persons (“QEPs”), for failing to register as a commodity pool operator, subject to certain conditions.

Form PF Amendments Delayed Again to October 2026: What Fund Managers Should Know

On September 17, 2025, The Securities and Exchange Commission (“SEC”), jointly with the Commodity Futures Trading Commission (“CFTC”), voted to extend the compliance date for the amendments to Form PF again. 

SEC Overcharging Case: What It Means for Private Fund Management Fee Practices

On August 15, 2025, the SEC announced charges against a Registered Investment Adviser for its management fee calculation practices for private fund clients. Each fund has a limited partnership agreement (“LPA”) that states the adviser is entitled to management fees and may receive transaction fees, including advisory fees, monitoring fees, and other fees, from portfolio companies.

Further Extension of Amended Form PF Compliance Date to October 2025

On June 11, 2025, the Securities and Exchange Commission (“SEC”), jointly with the Commodity Futures Trading Commission (“CFTC”), voted to further extend the compliance date for the amendments to Form PF that were adopted on February 8, 2024.

SEC No-Action Letter Clarifies 506(c) Exemption for Private Funds

The SEC recently issued a no-action letter with guidance on what constitutes “reasonable steps” to verify that a purchaser is an accredited investor.

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