Compliance efforts and practices of PE sponsors have improved significantly in the decade plus that Igor Rozenblit spent at the SEC, most recently as Co‑Head of the Private Funds Unit. Nonetheless, for all the ways that sponsors have leveled up their compliance measures and disclosures to investors, there remain notable ways that many sponsors’ practices are deficient. Whether it’s inadequate disclosures when affiliates act as service providers to funds or imprecise approaches to preparing valuations, the SEC continues to home in on practices that impact investors the most. In connection with his recent departure from the SEC, the Private Equity Law Report interviewed Rozenblit on the new consulting firm – Iron Road Partners – he formed and issues that should be top of mind for all sponsors. This second article in a two-part series outlines certain areas (e.g.
, expense allocations and investor disclosures) being prioritized by the SEC and suggests steps PE sponsors can take to avoid scrutiny. The first article
covered Rozenblit’s SEC tenure, the focus of his consulting firm and ways the Agency is addressing issues related to certain hot topics in the private funds industry. For additional commentary from Rozenblit, see “Perspectives From the Private Funds Unit
” (Feb. 11, 2016); and “Operations and Priorities of the Private Funds Unit
” (Sep. 24, 2015).