On January 13, 2021, the Committee submitted a letter to the SEC’s Asset Management Advisory Committee (“AMAC”) and its Private Investments Subcommittee on behalf of sponsors of registered closed-end funds that invest more than 15% of their assets in private equity funds (such funds, “registered funds of private funds”).


Historically, the staff of the SEC has taken the position in the registration statement disclosure review process that registered funds of private funds must limit their offerings to accredited investors. The Committee believes that the SEC staff should rescind this informal position in the circumstances outlined in its letter, because by doing so, the SEC staff would greatly expand the ability of retail investors to access professionally managed funds that make investments in private companies without compromising core investor protections.


Therefore, the Committee encourages AMAC and its Private Investments Subcommittee to consider the Committee’s position when formulating its own recommendations to the SEC.

The Committee’s letter can be found here.