Private Equity, Private Credit & Venture Capital

Managers and fund sponsors with a focus on the private capital markets present certain challenges to compliance practitioners given the public markets orientation of investment adviser regulation. Implementing an effective, yet undisruptive compliance program requires experience balancing the nuances of the business and efficiently installing conflict identification and management measures.

With a heavy client concentration of private equity and venture capital funds, our team has exposure to all sorts of structures – from the rudimentary to the highly complex – which allows us to be proactive in asking the right questions, offering anecdotes from past experiences, advising on risk and addressing matters before they materialize into substantive regulatory issues.

Today’s investing environment is characterized by innovation, and while the traditional buyout model where a fund buys, operates and sells a portfolio company still exists, the private equity/venture capital market has gotten increasingly more sophisticated. And with this sophistication comes the need for thoughtful, dynamic counsel, which is where we can advise on matters related to the following, amongst many others:

  • Co-investments and limited partner rights
  • Valued-added investors and operating partners
  • Information barriers and wall crossings
  • Principal and cross transactions
  • Affiliated arrangements and non-arm’s-length transactions
  • General partner (GP)-led restructurings
  • Allocation of expenses and operating costs
  • Limited Partner Advisory Committee (LPAC) structure and approval/consent process
  • Liquidations and distributions

With respect to venture capital, we routinely work with firms to evaluate their fund governing documents and investment portfolio to determine whether they qualify for an exemption from investment adviser registration. Whereas the availability the “private fund adviser” exemption requires a fairly simplistic analysis, the “venture capital adviser” exemption calls for a more in-depth review of a fund’s portfolio composition, borrowing allowances and redemption rights, which determines whether a firm needs to register as an investment adviser or can file as an exempt reporting adviser (ERA). Consistent with our universal dedication to pragmatism, we want to ensure our clients are well-informed about their regulatory options so they can pursue the path that is both legally sound and consistent with their LPs’ expectations and longer-term growth prospects.

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Learn more about how we support financial services firms' global regulatory, operational and governance needs.

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.
Greyline is pleased to announce that we are the recipient of the 2021 HFM U.S. Service Award in the Best Technology Firm – Newcomer category.