Since the Fifth Circuit vacated the SEC’s Private Fund Adviser Rules (“PFAR”), the Institutional Limited Partners Association (“ILPA”) has launched, updated or proposed updates to its four principal reporting templates, most recently including a draft updated Portfolio Company Template. Collectively, these developments underscore that many of PFAR’s transparency and comparability objectives remain important to
Bradley Schecter
Brad Schecter is an associate in the Corporate Department and a member of the Private Funds Group.
Brad has a general corporate practice, with an emphasis on representing U.S. and non-U.S. private investment fund sponsors in connection with a broad range of issues, including fund structuring and formation, investments, regulatory issues and compliance, internal governance, and day-to-day management and operations.
Prior to joining Proskauer, Brad practiced at Davis Polk & Wardwell LLP in New York, where he represented a range of financial institutions, institutional investors and companies in connection with distressed investment opportunities, corporate restructurings, bankruptcy proceedings, and regulatory issues.
SEC Eases Verification Burdens in Rule 506(c) Offerings
The SEC’s Division of Corporation Finance recently issued an interpretive letter[1] providing additional insight as to what constitutes “reasonable steps” to verify an investor’s accredited investor status under Rule 506(c) of Regulation D, a private offering exemption that permits general solicitation. Compared to Rule 506(b), which does not permit general solicitation, Rule 506(c) is…