November 30, 2023
On September 14, the Private Fund Adviser Rules were published in the Federal Register.
Given the complexity of the rules, it can be hard to keep track of which rules hit when and which rules are applicable to whom. This chart maps out each rule’s corresponding compliance dates, grandfathering provisions, and to whom it applies.
| Rule | Application | Grandfathering Provisions | Compliance Date | Compliance Deadline |
|---|---|---|---|---|
| Quarterly Statements | Only SEC-Registered PF Managers | No | 18 months after publication in the Federal Register | March 14, 2025 |
| Mandatory Private Fund Adviser Audits | Only SEC-Registered PF Managers | No | 18 months after publication in the Federal Register | March 14, 2025 |
| Adviser-Led Secondaries | Only SEC-Registered PF Managers | No | 12 Months after publication in the Federal Register for advisers with more than $1.5 billion of AUM
18 months after publication in the Federal Register for advisers with less than $1.5 billion of AUM |
September 14, 2024
March 14, 2025 |
| Preferential Treatment | All PF Managers | Yes; Allows some contractual agreements governing a private fund to remain in place that were entered into prior to the compliance date. | 12 Months after publication in the Federal Register for advisers with more than $1.5 billion of AUM
18 months after publication in the Federal Register for advisers with less than $1.5 billion of AUM |
September 14, 2024
March 14, 2025 |
| Restricted Activities | All PF Managers | Yes; Allows some written agreements for preferential liquidity and information rights that were entered into prior to the compliance date. | 12 Months after publication in the Federal Register for advisers with more than $1.5 billion of AUM
18 months after publication in the Federal Register for advisers with less than $1.5 billion of AUM |
September 14, 2024
March 14, 2025 |
| Written Annual Compliance Review | All SEC-Registered Advisers | No | 60 days after publication in the Federal Register | November 13, 2023 |
