On February 6, the SEC released an additional FAQ on the Marketing Rule, surprising many with long-past-live-date guidance on how Internal Rate of Return (IRR) should be calculated for funds using subscription credit lines. Unfortunately, the staff’s expressed position is inconsistent with prevailing market practice. Nonetheless, compliance is not optional.

On April 8, please join AIMA, Dechert LLP, and ACA Group for a webinar to focus on this issue.  During this session, we will discuss approaches being taken or considered by managers impacted by this guidance, as well as best practices to bear in mind. Attendee questions are welcome and encouraged.

Whether your firm has settled on a methodology or continues to grapple with this issue, we hope you will join us. To register, please click on the link below.

Panelists:

Shivani Choudhary, Managing Director, ACA Group

Michael McGrath, Partner, Dechert LLP

Julia Reyes, Partner, ACA Group

Suzan Rose, Senior Advisor, Government & Regulatory Affairs, AIMA