Between The Lines

Episode 03: A Deep Dive into the Private Funds Risk Alert

This week on Between The Lines, host Darren Mooney sits down with Greg Larkin, a Partner in the Private Investment Funds practice of Goodwin Proctor, to discuss the recent Risk Alert issued by the SEC’s Division of Examinations. Join the pair as they break down the Alert and offer insightful tips on how to react to the Alert’s observations.

Key Takeaways:

00:22   Show overview/ Guest introduction

00:32   Private fund advisers are under the microscope

04:33   Conduct inconsistent with governing fund documents

05:59   What can Hedge Funds do without LPACs?

07:53    Post-commitment fee calculation issues

11:35     Recycling of investment capital

14:50    Staying within your investment strategy

16:23    Notable issues related to advertising

20:15    Substantiation rules the day

21:00    Due diligence best practices

28:40    Incorporating new elements to portfolio investment oversight

33:28    Muddying the waters on hedge clauses

38:38    Closing thoughts: There’s more coming


Greg Larkin:  LinkedIn | Website 

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Darren Mooney

Partner and Co-Head of Business Development

Darren Mooney is a Partner and the Co-Head of Business Development at Greyline. Before joining Greyline, Darren served as deputy chief compliance officer of Partner Fund Management where he held primary responsibility for the compliance program of the second-largest hedge fund in the Bay Area. Prior to that, Darren spent five years providing compliance consulting services at Cordium and then ACA Compliance Group, where he led the company’s San Francisco office and west coast operations. In addition to providing ongoing consulting services to a variety of investment managers, including hedge fund, private equity, venture capital, real estate, quantitative and other wealth managers, Darren also regularly guided clients through the SEC registration process, implemented tailored compliance programs, supported clients’ live SEC exams, and served as an SEC-mandated independent compliance consultant following an SEC enforcement action. Darren’s other experience includes serving as deputy chief compliance officer and associate counsel at F-Squared Investments where he directly supported the compliance program during the investigation and subsequent enforcement regarding historical advertising practices. Darren has a B.S. in Economics from the University of Delaware and a J.D. from Suffolk University Law School. He is a member of the Massachusetts bar.

Annie Kong

Partner and Head of Venture Capital
Annie Kong is a Partner and Head of the Venture Capital Division at Greyline. She provides ongoing compliance consulting to investment advisers and manages client relationships. Prior to joining Greyline, Annie was part of compliance and operations at a long-only manager-of-managers that advised pension fund clients. While there, she conducted compliance and operational due diligence on SEC-registered investment advisers on the platform. She also oversaw and counseled on various legal matters across the firm. Annie has a B.A. in Economics from the University of California, San Diego, and a J.D. from the University of San Diego School of Law. She is an active member of the State Bar of California.
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