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Funds

Practices

Interval Funds

Our Investment Management group advises closed-end funds operating as interval funds, along with their sponsors, investment advisers and boards of directors, across the full life cycle of fund operations. Our work spans securities offerings, periodic repurchase programs, disclosure obligations, compliance frameworks and related regulatory matters.

We represent a diverse group of innovative interval fund sponsors and regularly advise funds conducting repurchase offers pursuant to both Rule 23c-3 under the Investment Company Act of 1940 and Rule 13e-4 under the Securities Exchange Act of 1934. Our team also provides strategic guidance on

marketing and distribution, including compliance with SEC advertising rules and FINRA requirements.

In addition, we assist sponsors in developing core structural and governance components, including fundamental policies governing periodic repurchase offers, tailored compliance manuals, portfolio valuation considerations and frameworks addressing the use of leverage and derivatives.

Representative Experience
  • Counseling on structural options available when establishing a fund
  • Providing business planning advice
  • Preparing and filing registration statements with the SEC and organizational documents with state authorities
  • Providing marketing, advertising and distribution advice, including facilitating third-party diligence reviews
  • Advising fund boards and/or independent directors/trustees on regulatory and corporate governance matters
  • Developing and implementing compliance programs and regulatory controls
  • Representing clients in mergers and acquisitions of investment companies, including assisting with due diligence
  • Advising on the creation of new products
  • Obtaining exemptive, no-action and similar relief from regulators
  • Drafting and negotiating agreements with fund service providers, lenders and broker-dealer intermediaries
  • Negotiating and evaluating investments in financial instruments, such as futures agreements, repurchase agreements, prime broker agreements, swaps and other derivatives
  • Preparing proxy statements, post-effective amendments and other regulatory filings
  • Working with fund auditors, fund accountants and fund administrators
  • Counseling on regulatory and business developments
  • Responding to regulatory inquiries and assisting in preparing for and responding to regulatory examinations
  • Representing clients in enforcement matters
  • Market-leading alternative registered fund practice with deep experience across interval funds, tender offer funds and other closed-end structures, including both RIC- and partnership-taxed vehicles
  • Dedicated team of eight attorneys with significant, ongoing focus on interval fund matters
  • Broad industry exposure, with clients investing across real estate, private credit and collateralized loan obligations
  • Long-term client partnerships, with continued representation post-launch and efficient pricing for ongoing support
  • Sophisticated transaction experience, including private fund conversions to interval fund structures, conversions to publicly traded closed-end funds, adviser- and sponsor-level M&A transactions and private offerings of interval fund shares