The SEC has enacted new regulations effecting required reporting on the part of hedge fund and PE fund advisers, some of which are focused on disclosing events within the the management structure and some of which are designed to signal economic concerns.  Various regulations become effective at the six-month and twelve-month marks after enactment.

Aside from rather straight-forward management matters such as removal of general partners and certain fund-termination events, large PE funds will be required to report general or limited partner claw-backs on an annual basis.

In my view, the most interesting regulations are aimed at alerting investors to possible investment performance trouble.  Reports are required as to events which could stress the fund or harm the investor, extraordinary investment losses, margin and default events, major events involving prime broker relationships, and important withdrawal and redemption events.

Commentary from SEC Chair Gensler noted the expansion of the power and impact of these private funds on the broader capital markets.  No doubt true, but these regulations surely also reflect the majority Commission view that tighter regulation and disclosure is required across the investment infrastructure landscape